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Lunchtime Discussion | ON THE PAST AND FUTURE OF GLOBAL JUSTICE With Ambassador David J. Scheffer
TUESDAY, DECEMBER 2, 2025
Ambassador David J. Scheffer was the first U.S. Ambassador at Large for War Crimes Issues and led the U.S. delegation to the UN talks establishing the International Criminal Court. He negotiated the creation of five war crimes tribunals and chaired the Atrocities Prevention Inter-Agency Working Group. Ambassador Scheffer also served on the Deputies Committee of the National Security Council and as Senior Adviser and Counsel to Dr. Madeleine Albright, the U.S. Permanent Representative to the United Nations. His latest book is The UN Charter: Five Pillars for Humankind (Springer 2025, co-author Mark S. Ellis).https://digitalcommons.nyls.edu/international_law_events_flyers/1024/thumbnail.jp
Professor Paul Dubisnky
Sheet 243B, Photo Box 4
Photographer: P. Decker STILL 2129294372https://digitalcommons.nyls.edu/pdubinsky/1000/thumbnail.jp
Professor Lawrence Grosberg
Sheet 249A, Photo Box 4
Photo Number 271https://digitalcommons.nyls.edu/lgrosberg/1003/thumbnail.jp
Career Panel | NYLS Alums Working in Product and Marketing Law
MARCH 3, 2025https://digitalcommons.nyls.edu/tricario_institute_events_flyers/1017/thumbnail.jp
2025 Tribeca Cybersecurity Summit
APRIL 4, 2025https://digitalcommons.nyls.edu/tricario_institute_events_flyers/1018/thumbnail.jp
The “Dealerization” of America: The SEC’s Misplaced Attempt at Broker-Dealer Registration for All
With the new administration in office, now is an appropriate time to reconsider the United States Securities and Exchange Commission’s (the “Commission” or “SEC”) efforts to require all securities traders to register as dealers. Over the last several years, the Commission has pursued enforcement actions against individuals and entities for allegedly operating as unregistered dealers in violation of Section 15(a)(1) of the Securities Exchange Act of 1934 (the “Exchange Act”). Notably, many of these actions involved convertible redeemable notes—debt instruments issuers can convert into common stock or redeem for cash. The SEC is now targeting established hedge funds, seeking expansive dealer registration even though such funds are exempt under Section 3(c)(1) of the Investment Company Act of 1940 (the “Investment Company Act”).
On February 6, 2024, the SEC adopted new rules expanding the definition of “dealer” to include entities that frequently engage in securities transactions. This article argues that (1) convertible redeemable notes are not securities, (2) hedge funds do not operate as brokers or dealers, and (3) the SEC’s attempt to expand the definition of “dealer” is improper