On November 12, the Public Investors Advocate Bar Association (PIABA), sent a letter to Ms. Vanessa A. Countryman, Secretary of the Securities and Exchanges Commission (SEC), to oppose the Proposed Exemptive Order Granting Conditional Exemption from the Broker Registration Requirements of Section 15(a) of the Securities Exchange Act of 1934 for Certain Activities of Finders. PIABA, of which Joseph Peiffer (Managing Shareholder of Peiffer Wolf), is a Director, “strongly opposes SEC File Number S7-13-20 (“Proposed Exemptive Order”) because it “frustrates the SEC’s mission to protect investors, contradicts significant SEC precedent regarding broker-dealer registration, and is contrary to the SEC’s warnings that allowing Finders to receive transaction-based compensation would incentivize abusive sales practices that registration/licensure is intended to regulate and prevent. Moreover, even assuming that the terms of the Proposed Exemptive Order may ‘clarify’ the regulatory status of Finders and/or benefit small and minority-owned businesses’ ability to raise capital, acting through an exemptive order is not the proper means to achieve those ends. This proposal should be withdrawn.”
You can read the full letter below:
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