Comment: SEC Proposed Exemptive Order from Certain Broker Registration Requirements

Oct 27, 2020

Vanessa A. Countryman
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
RE: File No. S7-13-20

Proposed Exemptive Order Granting Conditional Exemption from the Broker Registration Requirements of the Securities and Exchange Act

This is a response to the Securities and Exchange Commission’s (“SEC”) proposal to grant exemptive relief to permit natural persons (“Finders”) to engage in certain limited activities on behalf of issuers, without registering as brokers. Thank you for your efforts to facilitate the flow of capital to businesses, particularly emerging businesses.
While the proposed regulations are an excellent first step, an overall approach such as outlined below, would make any better and more sustainable regulations.

  • Only create one tier or class of Finder, similar to that of a Tier II Finder, and broaden the eligibility to include professional service providers such as lawyers, CPA’s, financial management consultants, etc.
  • Develop comprehensive guidelines and review, evaluate, and incorporate appropriate points from prior letters so only one set of comprehensive regulations exists. The intend would be to preserve the concept of a Finder but have robust regulations and guidelines.
  • Require on-line registration of a Finder with the SEC and confirmation or understanding and intended compliance with the regulations and guidelines, within three days of signing a contract with an issuer.

For the full comment in response to 45 questions posed by the SEC, please click here.

To view the full list of approved comments please visit the SEC comment page on this proposal.

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