Law360, New York ( October 27, 2014, 9:48 AM EDT) -- To ensure that broker-dealers (BDs) do not inadvertently facilitate an unlawful distribution of securities, the U.S. Securities and Exchange Commission has long required BDs to conduct a "reasonable inquiry" into the circumstances surrounding their customers' claimed registration exemptions for transactions involving unregistered securities. However, the SEC recently injected confusion into this area by reaching a $1 million settlement with two BDs whose due diligence procedures appear, at times, to have been quite thorough.[1]...
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