The FAQs also confirm (i) that the expanded vision of SEC staff on the broader vision of investors eligible for MUSII treatment, presented in the letter of the Nine Enterprises, contains all the provisions of the application of Rule 15a-6, and (ii) contains guidelines regarding capital requirements and other regulatory requirements for capital and registration for SEC-registered brokers who act as Chaperones in accordance with the rule 15a-6. Nine Firms` letter provided considerable relief by expanding the musii definition to all businesses (including businesses and partnerships) that hold or control more than $100 million in assets and investment advisors (including those not registered with the SEC) with more than $100 million in financial assets under management. The Nine Firms letter also allowed foreign comics to make some un accompanied oral communications with U.S. institutional investors and a few non-chaotic visits to MUSIIs and to transfer funds or securities directly to a U.S. institutional investor or MUSII in foreign securities transactions, although the activity of custodian of U.S. investment funds or securities is not permitted. The FAQs confirm that foreign comics that have entered into reflection agreements under Rule 15a-6 (a) (a) (3) under Rule 15a-6 (a) (2) may continue to transmit research reports directly to the institutions. Chaperones have no obligations regarding research reports if the Chaperon is not involved in the distribution of the report, although they are required to keep records of research reports when they are provided. After the monitoring exemption, foreign companies can discuss securities with U.S. investors without registering as U.S. brokers.
Instead, you can work through a FINRA Chaperone member company if the following conditions are met (note that this is not a comprehensive summary): Are you an investment professional who works outside the United States and wishes to present your investment mandates to U.S. institutional investors? If so, you may be able to work under a Chaperone agreement, as described in Rule 15a-6 of the Securities Exchange Act of 1934. A foreign comic and its American chaperone must put in place the appropriate compliance procedures for the companion to meet its obligations if the confirmations and statements provided by Foreign BD comply with these requirements.