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Category Archives: Foreign Broker-Dealers

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When in Rome Do as the Romans or At Least Play by the Rules

Posted in Broker-Dealer Registration, Broker-Dealer Regulation, Foreign Broker-Dealers, International Securities Regulation

Usually, we spend a fair amount of time advising our American broker-dealer clients, who do business overseas, that they have to follow the rules of those countries as well.  However, the “shoe” may sometimes be on the other “foot.”  See http://www.sec.gov/litigation/admin/2014/34-71593.pdf. Recently, a foreign broker-dealer was forced to pay a 9 figure judgment to resolve an action brought… Continue Reading

FOREIGN BROKER-DEALERS AND REGISTRATION EXEMPTION

Posted in Broker-Dealer Regulation, Foreign Broker-Dealers, International Securities Regulation

The Staff of the Securities and Exchange Commission Division of Trading and Markets issued advice on Securities Exchange Act of 1934 Rule 15a-6, involving registration exemptions for foreign broker-dealers.  See http://www.sec.gov/divisions/marketreq/faq-15a-6-foreign-bd.htm. In particular, Rule 15a-6 activities include when broker-dealers effect unsolicited securities transactions;  provide research reports to major U.S. institutional investors, and effect transactions in… Continue Reading