SEC Okays Wall Street Hiring Ex-Cons: With Paperwork, Of Course
Published Date: 7/16/2025
Notice
Summary
The SEC wants to keep Rule 194, which helps certain security-based swap dealers ask permission to let people with legal disqualifications work on their teams. This mainly affects 55 swap dealers, with only a few applications expected each year, taking about 30 hours total to handle. No big money changes here, just a smooth extension to keep things running on time.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Rule 194 Process Remains Available
Rule of Practice 194 stays in place so security-based swap dealers can apply for an order allowing an associated person who is subject to a statutory disqualification to effect or be involved in effecting security-based swaps on the dealer’s behalf. The rule sets the required showing, form of application, and items to address for natural-person associated persons.
Small Annual Paperwork Burden for Dealers
There are 55 registered security-based swap dealers and major security-based swap participants. The SEC estimates up to one Rule 194 application per year (about 30 hours) and up to three Rule 194(h) notices per year (about 6 hours each), for a combined estimated annual burden of approximately 48 hours across all dealers.
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