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Client Alert: SEC Proposes Limited Broker Registration Exemption for Two Classes of “Finders”


On October 7, 2020, the Securities and Exchange Commission voted to propose a new limited, conditional exemption from the broker registration requirements under Section 15(2) of the Securities Exchange Act of 1934, as amended for “finders” who assist issuers with raising capital in private markets from accredited investors.  The proposal, if adopted as proposed, would create two classes of finders, Tier I Finders and Tier II Finders.  Tier I and Tier II Finders would both be permitted to accept transaction-based compensation under the terms of the proposed exemption.  The Alert describing the proposal can be found here.