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In a statement, SEC Commissioner Hester M. Peirce noted: “Drawing the line between dealers and other active participants in our markets has long been challenging, and those challenges have only increased as our markets have evolved over the decades … While I have deep reservations about the breadth of today’s proposal, it addresses some important issues on which public comment will be valuable.” She believes that clarifying the scope of the term “dealer” is important but is not convinced that the proposal gets it right and thus she welcomes public comment.