Sifma Model Placement Agent Agreement

Both new agreements are for municipal brokers, brokers and stockbrokers who act as brokers. Federal securities laws require a broker to have an appropriate basis for recommending a guarantee to an investor. The use of these agreements will help brokers ensure that they comply with federal securities laws. Fourth, Alpine entered into a debt purchase agreement – also signed by Mr Gribben – in which it sold the investor Alpine (the 10% tax for brokers) against De Microcap. Microcap`s other creditors also entered into debt purchase agreements with the investor, under which each creditor sold its shares in Microcap`s debts to investors. The Securities Industry and Financial Markets Association complains of blocking the Securities and Exchange Commission`s injunction, which allows Muni non-dealers to facilitate certain private placements of municipal debt. A4.7. Rule 2111.03 excludes from the cover of the skill rule different types of educational communications, when they could be considered securities investment strategies. The rule states that certain communications are “excluded from the scope of Rule 2111 as long as they do not contain a recommendation of a particular title or title (alone or in connection with other communications[.]” 52 In particular, the rule provides a safe haven for the use of “[a]s., i.g.) are based on a generally accepted investment theory, (ii) as well as data on all key facts and assumptions that may influence the valuation of the asset allocation model or report developed by a reasonable investor, and (iii) in accordance with [FINRA Rule 2214] (requirements for the use of investment analysis tools) if the asset allocation model is an “asset allocation instrument” [FINRA 2214]. 53 Q8.3 Does the skill rule require a broker to have an agreement on the paper file that reflects a positive indication from an institutional client that he intends to make an independent judgment? [Note 12-25 (FAQ 26)] Third, Alpine became a creditor of Microcap through its mediation agreement – which Mr Gribben signed all – which generally agreed to pay Alpine 10% of the total debt the investor had acquired from Microcap`s creditors. A company could meet this requirement, for example by informing an institutional client, in a signed client agreement or in another document, that the institutional client, when assessing the recommendations, makes an independent judgment or a company uses its institutional client, conducts this discussion and (if it decides or circumstances require it) to have the interview documented to prove the positive indication of the institutional client.



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