Prohibited Compensation for Unregistered Introducers and Finders

What this video covers

• Why substance controls over label when regulators evaluate whether a payment to an unregistered person violates the rule, and why renaming a fee as a "consulting fee" or "marketing allowance" never cures the violation
• The definitive test for transaction-based compensation: whether the payment is tied to the business, accounts, or transactions an unregistered person brings in
• The four-step affirmative burden the firm must satisfy before paying any unregistered person, including the determination, reasonable support, recordkeeping, and periodic review requirements
• Why the three Securities and Exchange Commission (SEC) support mechanisms (published releases, no-action letters, and staff interpretations) are examples rather than a mandatory checklist, and what "among other things" really means on exam day
• The five conditions for the non-registered foreign finder exception and why double foreign status (both finder and customer) is strictly required
• The heavy documentation and disclosure obligations for foreign finder arrangements, including customer acknowledgment, FINRA availability of agreements, and trade confirmation disclosure
• The critical distinction between an issuer's own associated person (who may qualify for a safe harbor in distribution mechanics) and an outside, unregistered introducer (who is flatly prohibited from receiving transaction-based compensation)