🏦LTB
Series 79: Section 4
Series 79 practice questionhardBroker-Dealer Registration

A foreign bank’s U.S. branch provides advice incidental to securities transactions solely for existing commercial banking clients, does not accept securities orders, and does not hold itself out as a broker-dealer. Must the U.S. branch register as a broker-dealer under the Exchange Act?

  1. ANo, if the activity is truly incidental and the branch does not accept orders or act as a dealer✓ Correct answer
  2. BYes, because any advice relating to securities requires registration
  3. CYes, if the activity exceeds $100,000 per year in fees
  4. DNo, as long as the branch registers as an investment adviser
Explanation

Why ANo, if the activity is truly incidental and the branch does not accept orders or act as a dealer

The Exchange Act exempts banks whose advice is incidental and who do not execute securities transactions or hold themselves out as broker-dealers. The traps either overstate the registration requirement or confuse the issue with investment adviser registration.

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