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1 The SEC Remains in Search of and Is Looking for Finders
https://katten.com/the-sec-remains-in-search-of-and-is-looking-for-finders
Finders in violation of broker-dealer registration requirements may be subject to severe penalties under federal securities laws. Courts and the ...
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2 Finders Explained - Be Careful - SECLaw.com
https://www.seclaw.com/finders083101/
Being a finder means that he only introduces, he does not discuss, negotiate, or get involved in the transaction. However, the SEC may take a different view ...
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3 SEC Proposes Limited Exemptive Relief for Finders | Advisories
https://www.arnoldporter.com/en/perspectives/advisories/2021/01/sec-proposes-limited-exemptive-relief-for-finders
This proposed exemption is intended to supplement current broker-dealer regulation, and to provide clarity with respect to activities that would ...
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4 New Rules for Finders? Not So Fast… - Cutting Edge Capital
https://www.cuttingedgecapital.com/new-rules-for-finders-not-so-fast/
The SEC made a splash in October 2020 when it proposed a new set of ... even though they are not licensed as a securities broker-dealer.
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5 Key Considerations for Issuers and Potential Finders Under ...
https://www.jdsupra.com/legalnews/key-considerations-for-issuers-and-9057942/
... Under the SEC's Proposed “Finder” Exemption from Broker Registration ... the term “finder” or outlined what finders are permitted to do.
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6 SEC Approves Proposed Order Exempting Certain Finders ...
https://www.sewkis.com/publications/sec-approves-proposed-order-exempting-certain-finders-from-broker-registration-requirements/
The Finder has a written agreement with the issuer that covers services and compensation;; The Finder is not an associated person of a broker- ...
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7 SEC Commissioners divided over “new category” for finders -
https://joneskeller.com/sec-commissioners-divided-over-new-category-for-finders/
7 , 2020, would provide a new limited, conditional exemption from broker registration requirements for a “finder” who assists small business ...
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8 Permitted Finder Activities: SEC Proposes Long-Awaited ...
https://www.whitecase.com/insight-alert/permitted-finder-activities-sec-proposes-long-awaited-exemption
Permitted Finder Activities: SEC Proposes Long-Awaited Exemption ... law prohibition on the conduct of broker-dealer activities by a person ...
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9 Using an Unregistered Broker-Dealer for Capital Raising is a ...
https://www.darroweverett.com/using-an-unregistered-broker-dealer-for-capital-raising-is-a-risky-proposition/
October 2020 Finder's Exemption Proposal. The SEC has never formally recognized a “finders” exemption/exception from the securities laws. Although the SEC ...
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10 Proposed SEC Rules Provide Exemption for Finder's Fees
https://www.bakerdonelson.com/webfiles/Bios/Sloan%20in%20Bloomberg%20Law_CLEANED.pdf
Unfortunately, unless that “finder” has the appropriate license to act as a broker, securities laws prohibit paying that person “transaction-based compensation, ...
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11 Client Alert: Finding Investors–Are Finders Legal?
https://princelobel.com/client-alert-finding-investors-are-finders-legal/
However, few registered broker-dealers are willing to work on a ... however, generally, the SEC and federal law require that a finder be ...
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12 United States: SEC Proposed Order Exempts Certain Finders ...
https://www.mondaq.com/unitedstates/securities/1103226/sec-proposed-order-exempts-certain-finders-from-registering-as-broker
... 2020, the Securities and Exchange Commission (the "SEC") issued a ... from the broker registration requirements for certain Finder ...
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13 Finders and Unregistered Broker-Dealers - Venable LLP
https://www.venable.com/insights/publications/2018/05/finders-and-unregistered-brokerdealers
The distinction between a finder and a broker-dealer as classified by the Securities and Exchange Commission (SEC) can have significant ...
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14 Paying Finder's Fees to Unregistered Broker-Dealers Can Be ...
https://www.dbllawyers.com/unregistered-broker-dealers/
The Securities and Exchange Commission (SEC) has selected FINRA as the regulating entity to license and regulate broker-dealers.
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15 SEC Proposes 'Finders' Exemption From Broker Registration ...
https://www.clearygottlieb.com/news-and-insights/publication-listing/sec-proposes-finders-exemption-from-broker-registration-requirements
The Proposed Exemption is intended to provide clarity with respect to the ability of a Finder to engage in certain activities without being ...
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16 New Life For Finders? | Morrison Foerster
https://www.mofo.com/resources/insights/201008-new-life-for-finders
SEC Proposes Exemptive Relief for Finders to Help Private Issuers Raise Capital ... receive a finder's fee without having to register as a broker-dealer.
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17 BrokerCheck - Find a broker, investment or financial advisor
https://brokercheck.finra.org/
BrokerCheck helps you make informed choices about brokers and brokerage firms-and provides easy access to investment adviser information. search-icon ...
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18 Finders and Unregistered Broker-Dealers - K&L Gates
https://www.klgates.com/Finders-and-Unregistered-Broker-Dealers-Understanding-the-Risks-hosted-by-Strafford-6-22-2021
Fund managers and companies can be subject to SEC enforcement actions for aiding and abetting a finder's violation of the broker-dealer ...
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19 Broker-Dealer Registration and the Finder's Exception
https://www.squirepattonboggs.com/~/media/files/insights/publications/2017/11/family-office-insights-broker-dealer-registration-and-the-finders-exception/familyofficeinsightsbrokerdealerregistrationandthefindersexception.pdf
In fact, the SEC has stated that “any person receiving transaction-based compensation in connection with another person's purchase or sale of securities.
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20 Finders Fees and the Securities Laws | Startup GC
https://www.startupgc.us/post/finders-fees-raise-thorny-securities-law-issues
A concept etched into my mind from years as an SEC Enforcement lawyer is that "transaction-based compensation is a hallmark of broker-dealer ...
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21 SEC Proposes Conditional Exemption for Tier I and Tier II ...
https://www.proskauer.com/alert/sec-proposes-conditional-exemption-for-tier-i-and-tier-ii-finders-in-private-capital-raising
... 2020, the SEC voted to propose a conditional exemption from federal broker ... A Tier I Finder could not have any contact with a potential investor ...
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22 SEC Proposes Order to Exempt Certain Finders from Broker ...
https://www.shearman.com/perspectives/2020/11/sec-proposes-order-to-exempt-certain-finders-from-broker-dealer-registration
Under the Proposed Order, a natural person may act as a Tier I Finder by providing investor contact information to an issuer in connection with ...
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23 SEC Proposes a “Finder's Exemption”
https://dbmlegalservices.com/sec-proposes-a-finders-exemption/
On October 7, 2020, the Securities and Exchange Commission (“SEC”), by a 3-2 vote, proposed a conditional exemption from the broker-dealer registration ...
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24 Finders: Is The SEC Finally Ready To Clarify This Cloudy ...
https://www.crowdfundinsider.com/2021/04/174470-finders-is-the-sec-finally-ready-to-clarify-this-cloudy-issue-for-startups-and-other-private-companies/
With respect to the issuer utilizing a finder who is not registered as a broker-dealer, it can potentially lose the exemption it relied upon to ...
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25 Using An Unregistered Broker Is A Perilous Trap For The ...
https://www.morse.law/news/is-my-intermediary-a-finder-or-broker/
... determine whether the intermediary is a finder or broker according to the United States Securities and Exchange Commission (the “SEC”).
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26 Are You a Finder or an Unregistered Broker?
https://www.fedbar.org/wp-content/uploads/2013/12/feature2-dec13-pdf-1.pdf
In SEC v. Kramer (2011), the U.S. District Court for the Middle. District of Florida questioned the SEC's opinions regarding finders set forth in various fact ...
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27 The SEC's Proposed Exemptive Order for Finders in Private ...
https://www.jamsadr.com/blog/2021/the-secs-proposed-exemptive-order-for-finders-in-private-placements-an-uncertain-future-for-regulatory-certainty
In 1991, Mr. Anka requested no-action relief from SEC staff relating to his role in a ... Courts addressing the finder-as-broker issue use a ...
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28 Using Finders to Assist in Financings - Westlaw
https://content.next.westlaw.com/practical-law/document/Id168cd3def2911e28578f7ccc38dcbee/Using-Finders-to-Assist-in-Financings-Understanding-the-Risks-Associated-with-Unregistered-Broker-Dealers?viewType=FullText&transitionType=Default&contextData=(sc.Default)
... when a finder is deemed to be an unregistered broker-dealer, including risks arising from rescission rights, disclosure obligations and SEC sanctions.
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29 Can a Startup Pay a Transaction-Based Fee or Commission to ...
https://www.dwt.com/blogs/startup-law-blog/2021/03/transaction-based-fee-unlicensed-broker-dealer
For decades, the SEC has articulated a four-factor test to determine when a "finder" is required to register as a broker-dealer.
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30 SEC Proposes Conditional “Finder” Exemptions to Broker ...
https://www.paulweiss.com/practices/transactional/capital-markets/publications/sec-proposes-conditional-finder-exemptions-to-broker-dealer-registration-requirements?id=38113
SEC Proposes Conditional “Finder” Exemptions to Broker-Dealer Registration Requirements. Publications; more details ...
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31 The "Finder's" Exception from Federal Broker-Dealer ...
https://scholarship.law.edu/cgi/viewcontent.cgi?article=1758&context=lawreview
ker-Dealers and Investment Advisers, 17 SEC. REG. ... effect of the finder phenomenon on the scope of the broker-dealer registration requirements.
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32 Finders, Keepers: SEC Proposes New Exemptive Order for ...
https://www.wsgr.com/en/insights/finders-keepers-sec-proposes-new-exemptive-order-for-finders.html
Few registered brokers are willing to raise capital for finding investors in the ... The SEC takes the position that a finder who receives ...
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33 A Cautionary Note in the Use of Finders to Raise Capital
https://www.dbd-law.com/articles/a-cautionary-note-in-the-use-of-finders-to-raise-capital/
Important factors considered by the SEC in determining whether a finder is really a broker include (a) receiving transaction-based compensation, ...
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34 SEC Proposes Relief from Broker-Dealer Registration for ...
https://mintzedge.com/blog/sec-proposes-relief-from-broker-dealer-registration-for-certain-finders
To qualify as a Tier I Finder, a Finder's activities would be limited to providing contact information of potential investors: without having any contact with ...
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35 Securities Lawyer 101 - Finders Q & A
https://www.securitieslawyer101.com/wp-content/uploads/2014/12/Finders-Q-A.pdf
person who effects securities transactions to register with the SEC as a broker-dealer. Q. How can a Finder be compensated? A. Compensation of Finders based ...
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36 SEC Proposes New “Finder” Exemption Registration
https://www.kkwc.com/insights/sec-proposes-new-finder-exemption-registration/
Generally speaking, under the current regulatory framework, “brokers” that raise capital for companies must be registered as a broker-dealer.
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37 SEC UPDATES:
https://www.bclplaw.com/a/web/198246/Emerging-Themes-2021-SEC-updates-resources.pdf
The Finder is not an associated person of a broker-dealer; and ... Require finders to file any notice with the SEC of reliance on the exemption from broker ...
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38 SEC Proposes a Finder's Exemption from Broker-Dealer ...
https://www.willkie.com/-/media/files/publications/2020/10/secproposesafindersexemptionfrombrokerdealerregist.pdf
Willkie Farr & Gallagher LLP | willkie.com. 1. SEC Proposes a Finder's Exemption from. Broker-Dealer Registration Requirements.
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39 Keeping Capital Finders In Step With SEC Broker Regulations
https://www.law360.com/articles/1521755/keeping-capital-finders-in-step-with-sec-broker-regulations
Later, the individual also acted as a finder or closer in which, in addition to the foregoing, he attempted to close investments for which he ...
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40 New Exemptions for Finders in Securities Transactions
https://www.buchalter.com/publication/new-exemptions-finders-securities-transactions/
For many companies, using a “finder,” an individual or. ... the purchase or sale of any security unless such broker or dealer is registered with the SEC.
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41 Divided SEC Votes To Propose “Finder” Exemption From ...
https://www.goodwinlaw.com/publications/2020/10/10_09-divided-sec-votes-to-propose
Stay informed with our article: Divided SEC Votes To Propose “Finder” Exemption From Broker Registration and what this means for you.
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42 SEC Proposes Exemption from Registration for Certain Finders
https://www.akerman.com/en/perspectives/sec-proposes-exemption-from-registration-for-certain-finders.html
... “no-action”[3] letters for guidance on how to distinguish between “finder” and “broker” activities. The SEC's proposal, if adopted, ...
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43 SEC Proposes Conditional Broker Registration Exemptions for ...
https://www.nelsonmullins.com/idea_exchange/alerts/securities_alert/business-development-companies/sec-proposes-conditional-broker-registration-exemptions-for-finders
As the SEC considers implementation of the proposed Finder exemption rule over the coming months, we will provide additional guidance on the ...
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44 Laws Surrounding Finders Fees Continue To Evolve
https://www.startupblog.com/laws_surrounding_finders_fees_continue_to_evolve/
Securities laws do not specifically define the term finder, ... Broker-dealers must look to SEC rules to determine whether their activities ...
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45 SEC Proposes Conditional Exemption from Broker ...
https://www.coleschotz.com/sec-proposes-conditional-exemption-from-broker-registration-requirements-for-finders-assisting-small-businesses-with-capital-raising-efforts/
A Tier I Finder would not be permitted to have any contact with a potential investor about the issuer. Tier II Finders would be able to solicit ...
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46 SEC Proposes New Rules that would Exempt Certain “Finders ...
https://www.seyfarth.com/news-insights/sec-proposes-new-rules-that-would-exempt-certain-finders-from-registration-as-brokers.html
Past SEC guidance regarding exemption from broker-dealer ... a finder would be required to register as a broker is whether the finder was ...
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47 SEC proposes finder exemption from broker registration
https://www.mccloskeylawpllc.com/mccloskey-law-pllc-sec-proposes-finder-exemption-from-broker-registration.html
SEC proposes finder exemption from broker registration. October 19, 2020 | By Patrick T. McCloskey. On October 7, 2020 the Securities and Exchange ...
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48 Recent SEC Actions Easing Capital Raising Barriers for ...
https://www.varnumlaw.com/insights/recent-sec-actions-easing-capital-raising-barriers-for-smaller-issuers/
The proposal would provide a non-exclusive safe harbor from the broker registration requirements where a finder's involvement is limited to ...
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49 Finders – Part 2 | Securities Law Blog
https://securities-law-blog.com/2021/01/12/finders-part-2/
Following the SEC's proposed conditional exemption for finders (see HERE), ... New York has recently adopted a new finder's exemption, ...
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50 Divided SEC proposes conditional registration exemption for ...
https://www.dlapiper.com/en/us/insights/publications/2020/10/divided-sec-proposes-conditional-registration-exemption-for-finders/
Last week, the Securities and Exchange Commission (SEC) voted 3-2 along ... The regulatory uncertainty associated with finder versus broker ...
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51 SEC Proposes Exemption from Broker-Dealer Registration for ...
https://www.dorsey.com/newsresources/publications/client-alerts/2020/10/sec-proposes-exemption-from-broker-dealer
The finder is not subject to statutory disqualification, as that term is defined in Section 3(a)(39) of the Exchange Act, at the time of his or ...
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52 SEC Proposes Conditional Broker Exemption for Finders
https://www.lowenstein.com/news-insights/publications/client-alerts/sec-proposes-conditional-broker-exemption-for-finders-investment-management
The Finder does not engage in general solicitation. The potential investor is an “accredited investor” as defined in Rule 501 of Regulation D, ...
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53 SEC Proposes Exempting Finders, Subject to Compliance ...
https://www.akingump.com/en/news-insights/sec-proposes-exempting-finders-subject-to-compliance-obligations.html
To qualify as a “finder,” the natural person must: Not be an associated person of a broker-dealer and not be subject to a statutory ...
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54 SEC Proposes Conditional Finders Exemption From Broker ...
https://www.bhfs.com/insights/alerts-articles/2020/sec-proposes-conditional-finders-exemption-from-broker-registration-
Generally, brokers are required to register with the SEC under the Exchange Act. Under ... the finder is not an associated person of a broker-dealer; and ...
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55 SEC proposes exemption from broker ... - Withersworldwide
https://www.withersworldwide.com/ja-jp/insight/sec-proposes-exemption-from-broker-dealer-registration-for-finders
The proposed exemption, if adopted, would not only provide substantial relief and legal certainty for persons engaged in finder activities for issuers, but also ...
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56 Broker Registration Requirements: The SEC Proposes a ...
https://www.paulhastings.com/insights/client-alerts/broker-registration-requirements-the-sec-proposes-a-limited-conditional-exemption-for-finders
As a result, the ability of a finder to operate without a broker ... The SEC's Proposed Exemption for Finders – Tier I and Tier II Finders.
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57 New Proposed SEC Rule Would Allow Finders to Receive ...
https://www.hinshawlaw.com/newsroom-updates-hinshaw-alert-sec-finders-proposed-rule.html
In proposing this exemption, the SEC is seeking to provide greater ... 1) The finder cannot be an associated person of a broker-dealer.
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58 SEC Proposes Relief from Broker-Dealer Registration ... - Mintz
https://www.mintz.com/insights-center/viewpoints/2901/2020-10-12-sec-proposes-relief-broker-dealer-registration-certain
To qualify as a Tier I Finder, a Finder's activities would be limited to providing contact information of potential investors: without having ...
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59 SEC Proposes Exemptive Relief From Broker Registration for ...
https://www.wilmerhale.com/en/insights/client-alerts/20201028-sec-proposes-exemptive-relief-from-broker-registration-for-finders-for-small-companies
The Finder does not engage in general solicitation;; The potential investor is an “accredited investor” as defined in Rule 501 of Regulation D, ...
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60 Finders and Unregistered Broker-Dealers - Strafford
https://www.straffordpub.com/products/finders-and-unregistered-broker-dealers-understanding-the-risks-and-recent-developments-2022-06-21
... and SEC regulatory actions regarding unregistered broker-dealers. ... Finder-related exemptions, including M&A brokers, JOBs Act, ...
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61 SEC Proposes Conditional Exemption for Finders - Jones Day
https://www.jonesday.com/en/insights/2020/10/sec-proposes-conditional-exemption-from-brokerdealer-registration-for-finders
The SEC has proposed a conditional exemption from broker-dealer ... The finder is not an associated person of a broker-dealer; and ...
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62 Revenge of the Rat Pack; SEC Proposes Finders Exemption
https://www.polsinelli.com/publications/revenge-of-the-rat-pack-sec-proposes-finders-exemption
In order to be considered a “broker,” a person must be effecting ... There is no “finder exception” in the Exchange Act or SEC rules; ...
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63 The Danger of Paying Finder's Fees to Unregistered Broker ...
https://www.crossbordercounselor.com/the-danger-of-paying-finders-fees-to-unregistered-broker-dealers/
FINRA is the regulatory organization designated by the Securities and Exchange Commission (SEC) to license and regulate broker-dealers.
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64 Are You a Broker or a Finder? Does It Really Matter?
https://www.lexisnexis.com/legalnewsroom/banking/b/venture-capital/posts/are-you-a-broker-or-a-finder-does-it-really-matter
The SEC has consistently viewed the presence of transaction-based compensation as one of the key attributes of a broker's activity. According to ...
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65 At Last! – SEC Proposes Safe Harbors for Compensating ...
https://frostbrowntodd.com/at-last-sec-proposes-safe-harbors-for-compensating-finders-in-raising-capital/
The finder's compensation is commonly a transaction-based commission ... registration as a broker under federal and state securities laws.
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66 SEC Fires Another Salvo in the “Finder” Debate - Casetext
https://casetext.com/analysis/sec-fires-another-salvo-in-the-finder-debate
What are the take-aways from the SEC orders? Don't do the following if you aren't either a registered securities broker or associated with a ...
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67 SEC Proposes Broker-Dealer Registration Relief for Certain ...
https://www.kirkland.com/publications/kirkland-aim/2020/10/sec-proposes-broker-dealer-registration-relief
A “Tier I Finder” would be limited to providing potential investor contact information in connection with only a single capital raising ...
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68 SEC cracks down on unregistered broker-dealers in private ...
https://www.lexology.com/library/detail.aspx?g=b3fc9cc9-822b-4a29-938b-b48278adece4
The Securities and Exchange Commission (SEC) staff appears to be focusing on ... the SEC has been reluctant to create a “finder's exemption.
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69 Use Caution When Paying Finder's Fees in Securities ...
https://www.frantzward.com/news-blog/august-2022/use-caution-when-paying-finder-s-fees-in-securitie
Factors used to determine whether the recipient of a finder's or referral fee is acting as a broker have been developed through caselaw, SEC ...
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70 Clarifying the regulatory status of “finders” – the SEC proposes ...
https://www.reedsmith.com/en/perspectives/2020/10/clarifying-the-regulatory-status-of-finders
A long-standing issue in the area of broker regulation concerns the ... a finder's conduct in a specific instance triggered registration.
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71 Brokers and Finders in Securities Law - HG.org
https://www.hg.org/legal-articles/brokers-and-finders-in-securities-law-7818
By definition, a finder is not a broker. A finder does not regularly engage ... The SEC looks for prior or ongoing involvement in securities transactions.
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72 Finders Keepers - McCarter & English, LLP
https://www.mccarter.com/insights/finders-keepers-sec-proposes-to-allow-finders-to-receive-transaction-based-compensation-in-certain-limited-circumstances-without-having-to-register-as-a-broker-dealer/
SEC Proposes to Allow Finders to Receive Transaction-Based ... The finder must not be associated with a broker-dealer or otherwise ...
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73 SEC Proposes Additional Small Business Capital-Raising ...
https://www.chapman.com/publication-SEC-Small-Business-Capital-Raising-Broker-Dealer
SEC Proposes Additional Small Business Capital-Raising ... to require the finder to be a registered broker‑dealer; in the second instance, ...
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74 New Proposed Rule Would Give Non-Exclusive Safe Harbor ...
https://fridayfirm.com/news/main-blog/2021/01/20/new-proposed-rule-would-give-non-exclusive-safe-harbor-from-broker-registration
the finder cannot be an associated person of a registered broker-dealer, as defined under Section 3(a)(18) of the Securities Exchange Act, and ...
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75 SEC Continues to Deny Finders Exemption from Broker ...
https://www.martindale.com/legal-news/article_faegre-drinker-biddle-re_1071908.htm
... response to a no-action request that emphasizes the SEC's narrow interpretation of the finder exception from broker-dealer registration.
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76 NASAA-Comment-Letter-on-SEC-Finders-Proposal-111220.pdf
https://www.nasaa.org/wp-content/uploads/2020/11/NASAA-Comment-Letter-on-SEC-Finders-Proposal-111220.pdf
Exemption from the Broker Registration Requirements of Section 15(a) of ... While the Proposal would require a finder to form a reasonable ...
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77 Securities Law Alert - Phillips Nizer LLP
https://www.phillipsnizer.com/siteFiles/24381/Alert-SEC-TransactionBasedCompensation-6-10.pdf
SEC STAFF DECLINES TO PERMIT A FINDER IN A SECURITIES OFFERING. TO RECEIVE TRANSACTION-BASED COMPENSATION WITHOUT. BEING REGISTERED AS A BROKER-DEALER.
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78 SEC Proposes Rules Allowing for Unregistered Broker ...
https://whiteandwilliamsbusiness.com/finders-may-finally-be-keepers-sec-proposes-rules-allowing-for-unregistered-broker-dealers-to-participate-in-capital-raising-transactions-under-certain-circumstances/
The role and responsibilities that a finder can legally undertake is ... in “broker” or “dealer” activity must register with the SEC unless ...
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79 Neogenix Oncology: A Good Case Study on Securities Law ...
https://www.strictlybusinesslawblog.com/2012/10/24/neogenix-oncology-a-good-case-study-on-securities-law-noncompliance-by-a-high-growth-company-part-2-what-neogenix-did/
The term “broker” is defined in the Exchange Act as “any person ... [1] While the SEC has provided for a “finder exemption” for those who ...
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80 SEC Proposes Finders Exemption - Troutman Pepper
https://www.troutman.com/insights/sec-proposes-finders-exemption.html
... a Finder's LLC or other company is not eligible. That makes sense because the SEC views a broker-dealer license as unique to the entity ...
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81 SEC Proposes to Exempt Certain “Finders” from Broker
https://www.davispolk.com/sites/default/files/sec_proposes_to_exempt_certain_finders_from_broker_dealer_registration_requirements.pdf
transactions” to warrant broker-dealer registration. The so-called finder exception has been plagued with uncertainty, however, as the SEC ...
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82 Broker-Dealers, State Investment Advisers and SEC ... - DFPI
https://dfpi.ca.gov/broker-dealers-state-investment-advisers-and-sec-investment-advisers/
Broker-Dealers, State Investment Advisers and SEC Investment Advisers ... DFPI 25206.1, Statement of Information for Finder, PDF.
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83 SEC Proposes Much Needed Finder Exemption, and Paul ...
https://www.nyventurehub.com/2020/10/11/sec-proposes-much-needed-finder-exemption-and-paul-anka-must-be-singing/
Yet the general requirement that persons soliciting investors must register with the Securities and Exchange Commission as broker-dealers and be ...
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84 SEC Proposes “Finder” Exemption to U.S. Broker-Dealer ...
https://www.nauth.com/sec-proposes-%E2%80%9Cfinder%E2%80%9D-exemption-to-u.s.-broker-dealer-registration-requirements-to-facilitate-small-business-capital-raising/
On October 7, 2020, the U.S. Securities and Exchange Commission (the ”SEC”) proposed a new limited, conditional exemption (the “Proposed ...
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85 SEC Proposes Exemptive Relief for Finders - Morgan Lewis
https://www.morganlewis.com/pubs/2020/10/sec-proposes-exemptive-relief-for-finders
While an SEC proposal to exempt “finders” from broker-dealer registration ... Private Issuers – A finder would only be able to engage in ...
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86 SEC Proposes Exemption from Broker Registration for Private ...
https://www.ropesgray.com/-/media/Files/alerts/2020/10/20201019_AM_Alert.pdf?la=en&hash=8B46EB2FAFB9E1BAFECE91ADE13588A43967DE9D
person who is not a broker-dealer registered with the Commission.1. Background. Although the term “finder” has not been defined in any ...
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87 Safe Harbor for Permissible Capital-Raising Activities by ...
https://corpgov.law.harvard.edu/2020/11/05/safe-harbor-for-permissible-capital-raising-activities-by-unregistered-finders/
The proposed finders exemption from broker-dealer registration would ... The SEC's rule proposal restricts a finder from negotiating and ...
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88 SEC Proposed Exemption to Broker Registration Rules
https://burfordperry.com/sec-proposed-exemption-to-broker-registration-rules/
Previously, the SEC decided whether a Finder crossed into unregistered broker-dealer territory (and this violated securities laws) on a case-by-case basis.
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89 Recent SEC Actions Focus on Broker-Dealer Activity of Private ...
https://www.dechert.com/knowledge/onpoint/2013/4/recent-sec-actions-focus-on-broker-dealer-activity-of-private-fu.html
The Ranieri cases, in particular, are noteworthy because the SEC brought enforcement actions not only against a finder who was acting as an ...
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90 November 12, 2020 - CFA Institute
https://www.cfainstitute.org/-/media/documents/comment-letter/2020-2024/20201112.pdf
(the “SEC” or the “Commission”) on its proposed Exemptive Order Granting Conditional Exemption from the Broker Registration Requirements of ...
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91 Federal Register/Vol. 85, No. 198/Tuesday, October 13, 2020 ...
https://www.govinfo.gov/content/pkg/FR-2020-10-13/pdf/2020-22565.pdf
Capital Formation available at https://www.sec.gov/ ... defendant acted like a ''finder'' and not a broker where he introduced friends and ...
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92 AAndrew
https://cdn.laruta.io/app/uploads/sites/7/legacyFiles/uploadedFiles/MSBA/Member_Groups/Sections/Business_Law/Subcommittees/Securities_Law/Broker-DealerPlacementAgent.pdf
compensation gives the broker or finder a “salesman's stake” in the transaction. Herbruck, SEC No-Action Letter (June 4, 2002).
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93 New York Proposes Investment Industry Modernization and ...
https://www.mayerbrown.com/en/perspectives-events/publications/2020/05/new-york-proposes-investment-industry-modernization-and-finder-solicitor-registration-and-exam-requirements
Some defining traits of a finder were that a person could “find” merger ... SEC Guide to Broker-Dealer Registration (Apr. 2008) (mentioning ...
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94 Notice of Proposed Exemptive Order Granting Conditional ...
https://www.federalregister.gov/documents/2020/10/13/2020-22565/notice-of-proposed-exemptive-order-granting-conditional-exemption-from-the-broker-registration
The Finder is not an associated person of a broker-dealer; and ... See Transcript of the 39th Annual SEC Government-Business Forum on Small ...
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95 SEC proposes exempting certain finders from broker registration
https://us.eversheds-sutherland.com/NewsCommentary/Legal-Alerts/236658/SEC-proposes-exempting-certain-finders-from-broker-registration
the potential investor is an “accredited investor” as defined in Rule 501 of Regulation D under the Securities Act or the Finder has a ...
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96 Welcoming “Finders” in from the Cold in California
https://www.assetmanagementadvocate.com/2015/12/welcoming-finders-in-from-the-cold-in-california/
667, Section 25206.1 will exempt a “finder” from registration with the ... A person attempting to comply with the SEC's “private M&A broker” ...
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97 SEC Proposes Conditional Exemption for “Finders” Involved in ...
https://brownrudnick.com/alert/sec-proposes-conditional-exemption-for-finders-involved-in-capital-raising/
A Finder could not rely on this proposed exemption to engage in any other broker activity, such as facilitating a registered offering, ...
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