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This document constitutes comments from Farm Creek Securities, LLC addressing SEC Release Number 34-50980, discussing the regulatory treatment of broker-dealers and their exemption from the Investment
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How to fill out Comments on SEC Release Regarding Certain Broker-Dealers

01
Carefully read the SEC Release to understand the context and specific issues regarding broker-dealers.
02
Identify the sections in the release where your comments are needed or where you have specific insights to share.
03
Write your comments clearly and concisely, making sure to reference specific parts of the SEC Release when applicable.
04
Provide evidence or examples to support your comments to strengthen your position.
05
Review your comments for clarity and coherence before submitting.
06
Follow the submission guidelines provided in the SEC Release, ensuring your comments are submitted by the deadline.

Who needs Comments on SEC Release Regarding Certain Broker-Dealers?

01
Broker-dealers who are directly affected by the regulations outlined in the SEC Release.
02
Industry stakeholders, including financial firms, organizations, or individuals involved in the trading and selling of securities.
03
Regulatory bodies or advocacy groups that represent the interests of broker-dealers and the financial market.
04
Investors who may be affected by changes in broker-dealer operations and regulations.
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The Division's examinations will review the content of a broker-dealer's relationship summary, such as how the broker-dealer describes: (1) the relationships and services that it offers to retail customers; (2) its fees and costs; and (3) its conflicts of interest, and whether the broker-dealer discloses any
If the Commission finds that any registered broker or dealer is no longer in existence or has ceased to do business as a broker or dealer, the Commission, by order, shall cancel the registration of such broker or dealer.
Usually, the agency sends delinquency notices before taking action; if they are ignored, trading in the company's stock may be suspended without notice. At the same time, the SEC will initiate an administrative proceeding to revoke registration.
ingly, underwriters, brokers, market makers and other dealers doing business in the United States generally must register as broker-dealers in ance with Section 15(b) of the Exchange Act.
Broker Dealers If the promoter is a registered broker dealer and the recipient is a: “retail customer” covered by Regulation Best Interest, then these disclosure requirements do not apply. not a “retail customer” under Regulation Best Interest, then just the clear and prominent disclosure requirements apply.
All broker-dealers that sell securities to the public in the U.S. must be registered with the SEC and be members of a registered securities association (currently, FINRA). FINRA members must meet extensive conduct, operational and financial requirements.

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Comments on SEC Release Regarding Certain Broker-Dealers refers to the feedback and opinions submitted by interested parties regarding the Securities and Exchange Commission's (SEC) proposals or rules related to broker-dealers.
Any interested parties, including broker-dealers, industry associations, investors, and the general public, are encouraged to file comments on the SEC release.
To fill out comments, parties should provide clear, concise, and organized feedback, addressing specific elements of the SEC release, and submit their comments through the SEC's official submission channels.
The purpose is to gather diverse perspectives, insights, and data from stakeholders to inform the SEC's regulatory decisions and enhance the effectiveness of its rules concerning broker-dealers.
Comments must typically include the commenter's name, contact information, and a detailed discussion of their views on the specific proposals outlined in the SEC release.
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Securities and Exchange Commission broker-dealer Investment Advisers Act asset-based fees financial services investor protection Farm Creek Securities comment letter NASD SEC

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