In theory, at least one discoverer is simply responsible for introducing the parties to the negotiating table, but the services of a finder are sometimes used to support transactions involving the purchase or sale of securities. As such, federal and national securities laws are involved. Unfortunately, the analysis is not so simple. The uncertainty of a discoverer is characterized by two dry-action letters published over a seven-month period that yield different results. One of these non-action requests came from Hallmark Capital Corporation (“Hallmark”), a self-proclaimed “small business financial advisor and discoverer” that helps business owners raise capital, facilitates mergers and acquisitions, and provides strategic advice to businesses.” See Hallmark Capital Corporation of New York, New York., 2007 WL 18797999, 2 (2007). Hallmark`s activities, which were included in the “Help to Raise Capital” section, included “creating a confidential summary of information describing the transaction, identifying broker companies that may be interested in collaborating with the company, and arrugins that could lead to the broker`s obligation to raise funds by the client company.” This behaviour may appear to be a passive intermediary in the SEC`s previous filings, but the company has also attempted to “support mergers and acquisitions” and “strategic business advice.” The SEC found that Hallmark had to register as a broker-dealer if it intended to engage in these activities. When resellers of non-broker dealers are used, sections 15 can be largely eliminated by doing two things: the payment of research fees is a complex subject that requires careful legal analysis on a case-by-case basis and from one state to another. No agreement on the payment or receipt of these royalties should be concluded or implemented without seeking the advice of a competent lawyer. The problem is that some types of “research” are governed by securities laws. And if you`re using a discoverer who`s not a registered broker, you need to be especially careful as you do. In the business world, research fees are often paid to brand lawyers who do new business. These sellers also go above and beyond to attract new customers and return potential offers that you would never otherwise have obtained.

They deserve some sort of compensation for the transactions they bring to the company, and payment is often used as research fees.