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Mar 25, 2013

SEC Releases Responses to Frequently Asked Questions Regarding Rule 15a-6 and Foreign Broker-Dealers

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On March 21, 2013, the staff of the Division of Trading and Markets (the “Staff”) of the US Securities and Exchange Commission (the “SEC”) released responses reflecting the Staff’s views on frequently asked questions (the “FAQs”) relating to Rule 15a-6 (“Rule 15a-6” or the “Rule”) under the US Securities Exchange Act of 1934, as amended (the “Exchange Act”). The FAQs affirm, among other things, the SEC’s broad interpretation of Rule 15a-6 confirming the applicability of both the “Seven Firms” and “Nine Firms” to foreign broker-dealers, including those that use unaffiliated US-registered broker-dealers to intermediate transactions in accordance with Rule 15a-6(a)(3). This memorandum provides a brief background of Rule 15a-6 and highlights the important points included in the FAQs.

View full memo, "SEC Releases Responses to Frequently Asked Questions Regarding Rule 15a-6 and Foreign Broker-Dealers"

Authors and Contributors

Charles Gittleman

Of Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7317

+1 212 848 7317

New York

Russell Sacks

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7585

+1 212 848 7585

New York

Steven Blau

Associate

Financial Institutions Advisory & Financial Regulatory

+1 416 360 2154

+1 416 360 2154

Toronto