The SEC dismissed defendants in seven separate enforcement cases involving unregistered broker-dealer activity under Section 15(a) of the Securities Exchange Act of 1934. Defendants in these cases, including one ERA private fund manager, were charged with acquiring and selling billons of shares of microcap or “penny stocks” without registering as a securities dealer with the SEC, thereby avoiding certain regulatory obligations for dealers that govern their conduct in the marketplace, including regulatory oversight, financial reporting requirements, and maintaining required books and records. The SEC noted that the dismissals were based on a policy matter, not on any assessment of the merits of the claims alleged in the actions, and that its decision to seek dismissal of the actions “does not necessarily reflect the Commission’s position on any other case.” However, Commissioner Crenshaw criticized the dismissals as “ignore[ing] the laws enacted by Congress—namely fundamental registration requirements of the federal securities laws—as well as long lines of judicial precedent.” Crenshaw further noted that such action may signal a possible narrowing of the SEC’s interpretation of what a “dealer” is for purposes of the Exchange Act.