On August 24, 2011, Citi announced that Christy York has been appointed Managing Director and Head of Capital Introduction for its Prime Finance business in the Europe, Middle East and Africa (EMEA) region.  Pure capital introduction activities may not require broker-dealer registration, although many entities that make such introductions are already registered as broker-dealers.  However, more active intermediation and related compensation structures may require broker-dealer registration.  See “Is the In-House Marketing Department of a Hedge Fund Manager Required to Register as a Broker?,” Hedge Fund Law Report, Vol. 4, No. 10 (Mar. 18, 2011).  Moreover, intermediaries of hedge fund interests now have to contend with lobbying laws.  See “How Can Hedge Fund Managers Structure the Compensation of Third-Party Marketers in Light of the Ban On ‘Contingent Compensation’ Under New York City and California Lobbying Laws? (Part Two of Three),” Hedge Fund Law Report, Vol. 4, No. 13 (Apr. 21, 2011).