SEC’s David Blass Expands on the Analysis in Recent No-Action Letter Bearing on the Activities of Hedge Fund Marketers

The SEC recently issued a no-action letter (Letter) calling into question the long-held assumption that the receipt of transaction-based compensation necessarily requires broker registration.  See “SEC No-Action Letter Suggests That There May Be Circumstances in which Recipients of Transaction-Based Compensation Do Not Have to Register as Brokers,” Hedge Fund Law Report, Vol. 7, No. 7 (Feb. 21, 2014).  At a recent webinar, David W. Blass, Chief Counsel and Associate Director in the SEC’s Division of Trading and Markets, and others offered important insights on the applicability and interpretation of the Letter.  See also “Do In-House Marketing Activities and Investment Banking Services Performed by Private Fund Managers Require Broker Registration?,” Hedge Fund Law Report, Vol. 6, No. 16 (Apr. 18, 2013).

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