October 20, 2020
In my opinion, this proposed exemption from the Broker registration requirements would severely hurt small broker dealers as businesses would turn to non-licensed individuals to raise funds. There's already high competition among small broker dealers and this would further damage the ability to work in this industry.
Furthermore, this would blurry the line between a simple introduction and solicitation.
Finally, this proposed exemption would hurt small businesses as they would rely on non-licensed individuals who do not have the responsibility to report complaints, do not have to pay annual fees to the respective SROs, and do not have to abide by industry ethical standards.