If a foreign broker-dealer that does not have an associated U.S. registered broker-dealer includes research reports on its website, may it do so in reliance on the exemption under Rule 15a-6(a)(2)?
Rule 15a-6(a)(2) only permits a foreign broker-dealer to provide research to major U.S. institutional investors. The foreign broker-dealer may provide this research to a major U.S. institutional investor through a password-protected portion of its website. In the event the foreign broker-dealer provides research generally through its website it would need to take measures to ensure that its research does not generate transactional business with other U.S. investors.32 Question 28: May a foreign broker-dealer that does not have an associated U.S. registered broker-dealer express views on a research report it provides to major U.S. institutional investors under Rule 15a-6(a)(2) in public appearances and interviews conducted outside the U.S.? Would such public appearances and interviews be covered by Regulation AC? Would the answers to these questions change if content derived from these appearances and interviews is distributed by third parties that are in the business of disseminating i
Related Questions
- If a foreign broker-dealer that does not have an associated U.S. registered broker-dealer includes research reports on its website, may it do so in reliance on the exemption under Rule 15a-6(a)(2)?
- May foreign broker-dealers that are not associated persons of U.S. registered broker-dealers include their research reports in broadly distributed electronic databases?
- Can I access the mobile website from the application to check Flight Tracker or the Golf/Ski reports?
