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Ch. 27 · SEC / CFPB·Proposed·

Exempt finders and P2P lending; permanent EGC relief; ease small broker-dealer audits

Mandate would exempt small/intermittent finders from BD registration, simplify private-placement broker registration, exempt peer-to-peer lending from securities laws, make Title I EGC exemptions permanent, ease small BD burdens, and exempt non-custodial private BDs from PCAOB-registered audits.

Mandate

Mandate Ch. 27 (Financial Regulatory Agencies) — Entrepreneurial Capital Formation: exempt small and intermittent finders from broker–dealer registration and provide simplified registration for private placement brokers; exempt peer-to-peer lending from federal and state securities laws and reduce burden on Regulation CF debt securities; make Title I Emerging Growth Company exemptions permanent for all EGCs; reduce burden on small broker–dealers and exempt privately held non-custodial broker–dealers from PCAOB-registered firm audit requirements.

Undo plan

1) Define finders narrowly with transaction caps and disclosure to prevent unregistered brokerage. 2) Keep P2P lending under Truth-in-Lending/securities or banking oversight—do not create a securities-law void. 3) Sunset-review permanent EGC exemptions; restore investor disclosures where float/ownership thresholds grow. 4) Maintain independent audit quality standards even for non-custodial BDs via PCAOB or equivalent. 5) Verify: finder complaint rates; EGC disclosure gap studies.

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