SEC Footnote 74

SEC Footnote 74 deals with Alternative for Broker-Dealers Who Don’t Hold Customer Funds. The SEC issued Footnote 74 in July 2020, providing a much-needed substitute exclusively for firms engaging in a capital elevating activities (often Capital Acquisition Brokers). The guidance of SEC Footnote 74 refers to such broker-dealers as Non-Covered Firms. Non-Covered Firms who only

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