What was, essentially, a blow to EB-5 project marketing efforts -- in the United States and overseas -- was issued by the Securities and Exchange Commission (SEC) in the form of denial of a request for a "no-action" letter.
Brumberg Mackey & Wall, PLC, (BMW) sought to assist a client in raising money for its business interests, and asked whether it could take a percentage of funds raised without registering with the SEC as a broker or deal.
The SEC said no. "[T]he Staff believes that the receipt of compensation directly tied to successful investments in [the client's] securities by investors introduced to [the client] by BMW (i.e., transaction-based compensation) would give BMW a "salesman's stake" in the proposed transactions and would create heightened incentive for BMW to engage in sales efforts. Accordingly, the Staff believes that your proposed activities would require broker-dealer registration."
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