WHY WILL BUYERS AND SELLERS OF DOGS FOR HUNTING, SECURITY AND BREEDING PURPOSES BE LICENSED UNDER SA 3723?
Previously, AWA’s entire determination of who was a federally licensed dog seller (“dealer”) hinged on the type of sale involved – wholesale or retail. SA 3723 discards that regulatory structure and substitutes one that requires that most dealer determinations be based on numbers of dogs sold or litters bred, without regard to wholesale or retail sales. The critical problem is that SA 3723 leaves a key existing AWA provision unchanged. The term *dealer* means any person who buys, or sells any dog for hunting, security, or breeding purposes This is in conflict with the numerical criteria set out above. Why are hunting and security dog owners singled out and herding, working and toy breed owners ignored? Does this mean that all sellers of intact dogs are to be licensed, but not those selling sterilized animals? The reason that this provision hasn’t been an active concern before today is that it has not been enforced. USDA took four years to write the “purposes” implementing rule and it w
