Research reports.  Foreign comics may, directly or indirectly, provide all U.S. investors with research reports (i) pursuant to Rule 15 bis-6 (a) (a) or (ii) to all U.S. investors, indirectly through SEC-registered brokers, who are responsible for the content of the research report pursuant to Rule 15a-6 (a) (a) (3) chaperoneing agreements. Answer: Yes. Although the non-action position in the Nine Companies letter was based on statements on specific facts and conditions that included membership between the nine registered brokers mentioned in the letter and their related foreign brokers, the staff also fixed the position taken in the letter for a foreign broker who entered into an accompanying agreement with an unrelated broker.18  Rule 17a sets the reference period. for which these records must be kept. Registered broker dealers. The seller of brokers chaperoning us must provide a written record of the above information and consents for notification of the procedure by related persons of the foreign broker in his office and make them available to the SEC upon request. (return) The FAQs confirm that foreign comics that have entered into reflection agreements under Rule 15a-6 (a) (a) (3) under Rule 15a-6 (a) (2) may continue to transmit research reports directly to the institutions.
Chaperones have no obligations regarding research reports if the Chaperon is not involved in the distribution of the report, although they are required to keep records of research reports when they are provided. Answer: a registered broker who has entered into an accompanying agreement with a foreign broker, rule 15a-6 (a) (3), is subject to a minimum of $250,000 of required net capital, unless the chaperoneing company dealer has entered into a fully disclosed port contract with another registered broker-dealer who has agreed in writing to comply with the SEC`s financial liability rules with respect to the agreement. A chaperone dealer who has entered into such an agreement is subject to a minimum net capital requirement of $5,000 or any other higher amount required by Rule 15c3-1 based on the broker`s and trader`s activities. Answer: Yes. Rule 15a-6 (a) (2) (2) allows a foreign broker to: Provide research reports to large U.S. institutional investors and conduct transactions on securities examined in connection with or for these large institutional investors in the United States, provided certain conditions are met.17 The rule does not require that the distribution be made by a registered broker-dealer , even if the foreign broker has a chaperoneing agreement with a registered trader. In addition, the chaperone dealer would not have any obligations regarding a research report if the chaperoneing brokerage dealer was not involved in the distribution (i.e. if the research was distributed directly by the foreign broker to large institutional investors in the United States) and that it would not be necessary to keep a copy of a research report that he never had. Question 8.1: Does the answer to question 8 mean that a foreign broker should have a cover agreement with a registered broker to rely on the Seven Firms Letter? 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)?  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. Rule 15a-6 is considered a great success in terms of the ability for foreign comics to access the United States, especially those with chaperone arrangements.