Report and Recommendations of the Task Force on Private Placement Broker-Dealers

This Report and Reccomendations has been preparted by a Task Force of representatives from the Business Law Section of the American Bar Association. The impetus for this Report is a widely held perception that there exists a major disconnect between the various laws and regulations applicable to securites brokerage activities and the methods and practices actually in daily use by which the vast majority of capital is raised to fund early stage businesses in the United States. This vast and pervasive "gray market" of brokerage activity creates continuing problems for the unlicensed brokers, the businesses which rely upon them for funding, attorneys and other professionals advising both the brokers and businesses, and, last, but not least, the federal and state regulators who are charged with the obligation to enforce laws and regulations that are out of step with current business practices.