FINDERS AND BROKERS: Who to pay?

Lately I have gotten a number of questions about raising capital for small companies. It usually starts with a question about someone who has good connections and believes that she can raise money for the company but wants to receive some type of compensation.

SEC Chair Asserts Authority Over the Staff

  SEC Chair, John Clayton, issued a statement on September 14, 2018, that on its face should not have caused any concern. We have always known that the Commission oversees the work of the staff and that an individual staff member cannot bind the Commission. We know that No-Action letters are not binding although we […]

Private Placement Brokers and Finders, Oh My

In October of 2016, the SEC approved FINRA rules allowing for the registration of limited purpose broker-dealers, called capital acquisition brokers or CABs (see my blog post on November 1, 2016). This set of rules came about from a No-Action letter issued the year before that granted a no-action position for a very limited exemption […]

Re-Engaging

When I started my blog  I had a vision of a dialogue among professionals engaged in the securities industry. But at that time I was more of a lawyer than an entrepreneur. Lawyers believe that everyone wants to understand the smallest detail about a law. What I have found is that clients and prospective clients […]