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Is a broker-dealer considered a distribution participant if its sole responsibility with respect to a call for redemption of warrants is to send notices to warrant holders of the call for redemption and it receives a fixed fee for its services?

broker-dealer distribution participant redemption respect responsibility send sole Warrants
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Is a broker-dealer considered a distribution participant if its sole responsibility with respect to a call for redemption of warrants is to send notices to warrant holders of the call for redemption and it receives a fixed fee for its services?

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No. If the broker-dealer performs only ministerial duties and receives a fixed fee consistent with its limited role (i.e., its compensation is not based on the success of the offering and is a customary amount), it will not be deemed a distribution participant.

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