The SEC Stance On Transaction-Based Compensation

Law360, New York (June 28, 2010, 6:21 PM EDT) -- For many years, people who assist companies either in finding investors or a purchaser for the business have been advised that, if they only make introductions and do not otherwise participate actively in the transaction, they should be able to avoid registering as a broker under Section 15 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”).

Until a recent no-action letter, this was thought to be true even if the financial intermediary received a percentage of the amount raised as compensation, since...
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