The Securities and Exchange Commission has proposed an exemptive order to allow unregistered, unsupervised individuals to engage in a broad array of brokerage activities, in return for transaction-based compensation, without having to register as brokers. CFA submitted a comment letter criticizing the agency for proposing to dramatically expand the activities these private market intermediaries can engage in without being subject to appropriate regulatory requirements. “Even if you assume that clarifying the regulatory status of finders would benefit small company capital formation, this proposal is not the way to go about it, and acting through an exemptive order is not the proper means to achieve that end. This proposal, at least as it pertains to Tier 2 Finders, should therefore be withdrawn,” the letter states.