![]() Established an expanded interpretation of the definition of “major U.S.7 Among other things, the Nine Firms Letter: Affiliated Foreign Broker-Dealer either registering with the SEC as a broker-dealer or effecting the transactions in accordance with Rule 15a-6. Affiliated Foreign Broker-Dealer (as modified to reflect the addition of two additional firms party to the letter) engaged in certain activities without the U.S. 6 The following year, staff informed counsel to nine registered broker-dealers (including all of the firms party to the Seven Firms Letter) that they would not recommend enforcement action to the SEC if any U.S. Affiliated Foreign Broker-Dealer either registering with the SEC or effecting the transactions in accordance with Rule 15a-6. Resident Fiduciary (as defined therein) for Offshore Clients (as defined therein) without the U.S. Affiliated Foreign Broker-Dealer”) effected transactions in Foreign Securities (as defined therein) with a U.S. For example, in a 1996 letter to counsel for seven registered broker-dealers, staff indicated that they would not recommend enforcement action to the SEC if a foreign broker-dealer affiliated with any of the firms named in the letter (each, a “U.S. Since that time, the staff has provided guidance on the operation of Rule 15a-6 in various no-action letters. broker-dealer registration requirements.” 5 institutional investors through foreign broker-dealers and the research that they provide, consistent with maintaining the safeguards afforded by broker-dealer registration,” and “to provide clear guidance to foreign broker-dealers seeking to operate in compliance with U.S. ![]() In adopting Rule 15a-6, the SEC sought “to facilitate access to foreign markets by U.S. citizens resident abroad, and foreign branches and agencies of U.S. ![]()
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