A lot of people seem to not be happy with this though, even outside the usual crypto community. The main criticism is that the definition of dealer feels contradictory, which gives the SEC a lot of power that they never have to begin with. Judging from the tone of the article and some comments about it, I second the opinion that a lawsuit or scrutiny will come into existence sooner or later. It feels like the SEC intentionally breached several things and set the bar so high that they can still earn something even if they lose the lawsuit.