Rule 15a-6 provides a conditional exemption that allows foreign broker-dealers to interact with certain US persons without registering as a US broker-dealer, provided those interactions are chaperoned by a registered US broker-dealer. The chaperone assumes defined responsibilities under the rule, including participating in communications between the foreign broker-dealer and US investors, maintaining required books and records, and ensuring that the engagement structure satisfies the conditions of the exemption.
For foreign financial institutions and broker-dealers that have established research capabilities, deal flow, or investor relationships they want to bring to the US market, the absence of a qualified chaperone is often the sole structural obstacle. Stonebridge Capital Partners fills that role with the regulatory infrastructure, FINRA membership, and institutional process required to support compliant cross-border engagement.
The firm works with foreign broker-dealers across a range of engagement types, including research distribution to US institutional investors, investor meetings and roadshows involving US counterparties, and transaction-level introductions where a US-registered intermediary is required. Each arrangement is structured to reflect the specific nature of the foreign firm’s activity and the investor base being accessed.
Chaperoning engagements are conducted in accordance with SEC Rule 15a-6 and applicable FINRA requirements. All services provided through Stonebridge Capital Partners LLC, Member FINRA (CRD# 328918).
