Earlier in 2023, the SEC reopened the comment period on its proposal to amend the definition of an “exchange” under Rule 3b-16 of the Securities and Exchange Act. Already a sweeping proposal, the reopening release clarified that crypto-market participants would, for the most part, be within scope. Newly received comments are currently under review.
Relatedly, the SEC recently finalized a number of important initiatives, including offering significant amendments to the rules governing money market funds; shortening the transaction settlement cycle from T+2 to T+1; and making significant changes to the rules pertaining to advisers to private funds.
Finally, in November 2022 the SEC's Division of Trading and Markets issued a no-action letter delaying the application of amended Rule 15c2-11 to fixed income securities trading in OTC markets. Private issuers of debt securities, in particular securities issued under Rule 144-A and Regulation S, now have until January 4, 2025, to comply with the new public information requirements. While this provides relief in the short term, the issues of costs and compliance will come up again toward the end of 2024, with the new compliance deadline looming.