The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

Foreign Securities Firm Exemption Foreign securities firms may approach Type 1 or Type 2 FIBO • Foreign securities firms may approach certain types of institutional investors but only from offshore => Must carefully check whether the target investor and the action fall within the scope of this exemption because it is a very narrowly tailored and very complicated exemption • A foreign securities firm may accept orders if an investor voluntarily approaches the foreign securities firm • Asset managers cannot rely on this exemption Morgan Lewis 13

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