Rule 15a-6 & Chaperoning Services

SEC RULE 15a-6 “Chaperoning” 

Global Alliance Securities bridges the gap between foreign-registered broker-dealers and U.S. based institutional investors by specializing in a set of services to non-U.S. broker-dealers under the SEC Rule 15a-6* commonly referred to in the financial industry as “chaperoning”.  The Global Alliance team has over 18 years of experience in chaperoning services.   These services assist non-U.S. broker-dealers to gain access to Major U.S. institutional and U.S. institutional investors.  SEC Rule 15a-6 defines these types of investors in the following manner:
Major U.S. Institutional Investor means a person that is:

  • A U.S. Institutional Investor that has, or has under management, total assets in excess of U.S. $100 million; provided, however, that for purposes of determining the total assets of an investment company, the investment company may include the assets of any family of investment companies of which it is a part; or

  • An investment adviser registered with the SEC under Section 203 of the United States Investment Advisers Act of 1940 that has total assets under management in excess of U.S. $100 million.

U.S. Institutional Investor means a person that is:

  • An investment company registered with the SEC under Section 8 of the United States Investment Company of 1940; or

  • A bank, savings or loan association, insurance company, business development company, small business investment company, or employee benefit plan defined in Rule 501(a)(1) of Regulation D under the United States Securities Act of 1933 (the “Securities Act”); a private business development company as defined in Rule 501(a)(2) of the Securities Act; an organization described in Section 501(c)(3) of the Internal Revenue Code; as defined in Rule 501(a)(3) of the Securities Act; or a trust described in Rule 501(a)(7) of the Securities.

The Global Alliance professionals lean on their long and extensive experience in international trading, settlement and investment banking while helping foreign securities firms to navigate complexities of complying with appropriate U.S. rules and regulations relevant to offering of foreign securities and services to U.S. institutional investors.
In acting as “chaperone” to foreign brokerage firms, Global Alliance “effects”, in accordance with SEC Rule 15a-6, transactions of the foreign brokers with US institutional investors, provide solutions for settlement, custody and customers communications in accordance with relevant US regulations and compliance practices.

“Chaperoning” arrangements with each foreign securities firm is custom tailored to fit the needs of their respective market, smooth settlement of transactions and clear communications between foreign broker and US institutional investor under patronage and guidance of Global Alliance acting as “chaperone”.

For additional information on our Chaperoning Program please contact John P. O’Shea: joshea@gassec.com, Jennifer O’Shea: jenoshea@gassec.com or Arkadiy Neyman: aneyman@gassec.com.

Publication Links regarding SEC Rule 15a-6
www.sec.gov/divisions/marketreg/rule15a-6.htm
www.sec.gov/divisions/marketreg/faq-15a-6-foreign-bd.htm
SEC Charges Non-US Brokerage Firms with Violating U.S. Registration Requirements.

*Rule 15a-6 affords certain exemption from US registration requirements to foreign broker-dealers utilizing “chaperoning” services of properly registered US securities firms.

SEC Charges HSBC’s Swiss Private Banking Unit With Providing Unregistered Services to U.S. Clients. Firm Admits Wrongdoing to Settle Case

November 25, 2014

Washington D.C., Nov. 25, 2014 — The Securities and Exchange Commission today charged HSBC’s Swiss-based private banking arm with violating federal securities laws by failing to register with the SEC before providing cross-border brokerage and investment advisory services to U.S. clients. HSBC Private Bank (Suisse) agreed to admit wrongdoing and pay $12.5 million to settle the SEC’s charges. “HSBC’s Swiss private banking unit illegally conducted advisory or brokerage business with U.S.