The FAQs confirm that foreign comics that have entered into reflection agreements under Rule 15a-6 (a) (a) (3) under Rule 15a-6 (a) (2) may continue to transmit research reports directly to the institutions. Chaperones have no obligations regarding research reports if the Chaperon is not involved in the distribution of the report, although they are required to keep records of research reports when they are provided. Let us suppose, for example, that the Boston Fireman`s Pension Fund wants to buy one million shares of a South African telecommunications company. The South African broker, if he has a written agreement with an American broker (the ”Chaperone Broker”), may sell the shares of Boston Fireman`s Pension Fund if (1) the chaperone broker has examined the company and its South African staff; (2) The South African company and its staff agreed to return the proceedings to the United States and agreed to establish, upon request, records to U.S. regulatory authorities; (3) the chaperone broker records the transaction on his books and sends a confirmation in accordance with Rule 10b-10 of the transaction (or ensures that a transaction has been made, and it has a record of it); and (4) the U.S. company (or its clearing company) is prepared to go up on the disc and collect a capital tax if the South African company does not provide the shares that the pension fund has purchased. A working company with only a minimum of $5,000 in net capital can act as a broker of 15a-6 Chaperone if the clearing company agrees in writing to impose a capital fee on the failure of a foreign broker. If the clearing company does not do so, an entry company may still act as a 15a-6 chaperone broker, but the entry company must itself have $250,000 of net capital and collect a capital charge in the event of a default. The letter from Nine Firms provided considerable relief by expanding the musii definition to all businesses (including businesses and partnerships) that hold or control more than $100 million in assets and investment advisors (including those not registered with the SEC) with more than $100 million in financial assets under management. The Nine Firms letter also allowed foreign comics to make some un accompanied oral communications with U.S. institutional investors and a few non-chaotic visits to MUSIIs and to transfer funds or securities directly to a U.S.

institutional investor or MUSII in foreign securities transactions, although the activity of custodian of U.S. investment funds or securities is not permitted.