Individuals or entities who assist companies in finding financing or an M&A partner

Finders often don't comply with federal and state registration requirements

• Misperception that requirements don't apply to
  one-off or occasional engagements
• Even though SEC no-action relief has been limited to where finders only provide referrals without participation in negotiation or valuation

Registration requirements have been criticized as being unduly burdensome

• Inhibit early-stage capital raising

"Making Finders Viable" (2004)

• From SEC Roundtable

Law firm memos

• Miller Nash (2004)