Chaperoning Agreement Definition

Question 10: What is the net capital required for a registered broker who has entered into an accompanying agreement with a foreign broker in accordance with Rule 15a-6 (a) (3)? Answer: Yes. For reasons similar to those of the answer to question 6, the Staff considers that the position taken in the letter of the Seven Enterprises applies to a foreign broker, whether the registered broker with whom he entered into a support contract is a subsidiary or not. 2 For the purposes of this FAQ, the term “chaperoneing broker dealer” refers to a registered broker who meets all the requirements of Rule 15a-6 (a) (a) (3) (iii), including, among other things, the conduct of transactions, the issuance of confirmations, the keeping of books and records, participation in oral communications and the collection of certain assurances and consents. Answer: No. An importing broker cannot invoke the 15c3-3 (k) (2) (2) (i) exception rule and maintain the net capital of $100,000, while accompanying a foreign broker in accordance with Rule 15a-6 (a) (3) and is based on the letter of nine companies. As indicated in the answer to question 10, a registered broker who enters into an accompanying agreement with a foreign broker pursuant to Rule 15a-6 (a) (3) (3) is subject to a support contract, of a minimum of $250,000 of minimum net capital, unless the chaperoning company`s dealer has entered into a fully disclosed transport agreement with another registered broker-dealer who has agreed in writing to comply with the SEC`s financial liability rules. chaperone agreement23. which maintains a minimum net capital of at least $250,000 and is based on the exception rule 15c3-3 (k) (2) (i) or a broker who charges in full in accordance with rule 15c3-3 may act according to the letter of Neuf-Firms. This net capital requirement is based on the companion`s responsibilities under Rule 15 bis-6, point a) (3) iii). However, as noted in the answer to question 4, the chaperone broker dealer still reserves the obligation to ensure that any confirmation or account card sent to a U.S. institutional investor or large institutional investor in the United States meets all applicable U.S. requirements, including Rule 10b-10 under the Exchange Act and current self-regulation rules. In addition, the confidence placed in the foreign broker in establishing and sending bank confirmations or statements would in no way relieve the dealer of chaperoning brokers of his ultimate responsibility for respecting legal or regulatory responsibilities under federal securities laws.

[3] As a general rule, foreign comics with existing support agreements are allowed to have more contacts and transactions with U.S. investors than those that do not. A chaperone agreement requires a U.S.-registered broker to assume responsibility for the implementation and oversight of certain activities related to the contacts and transactions of U.S. investors in a foreign comic book. On March 21, 2013, U.S. Securities and Exchange Commission (“SEC”) Department of Commerce and Markets staff responded to frequently asked questions (“FAQs”)[1] regarding U.S. Rule 15a-6.