Silent Rich is committed to the highest standards of compliance and professional conduct. We facilitate strategic business connections while adhering to all relevant regulations and ethical guidelines. This page clarifies our non-registered broker-dealer status and details how our connectors operate within SEC guidelines. Below, you will find detailed information on our compliance policies and professional standards.

Silent Rich is not a registered broker-dealer and does not provide investment advice or facilitate securities transactions. Our services are limited to making introductions and sharing general information about opportunities. Members and clients are responsible for conducting their own due diligence and seeking appropriate professional advice before engaging in any transactions.

Silent Rich operates fully within SEC regulations, ensuring compliance with all relevant laws and guidelines. We do not provide investment advice, manage client assets, or engage in securities transactions. Our activities are limited to making introductions and sharing general information, which aligns with SEC safe harbor provisions. Additionally, we adhere to anti-money laundering best practices and do not engage in solicitation or advertising of securities. Our connectors act solely within the guidelines provided by SEC no-action letters, focusing on introductions and information sharing.

Investment Advisers Act of 1940

• Relevant Section: Section 202(a)(11)
• Summary: This act defines an investment adviser as any person or firm that, for compensation, engages in the business of advising others about securities. Silent Rich does not provide investment advice or manage client assets, thus not falling under the definition of an investment adviser.

Securities Exchange Act of 1934

• Relevant Section: Section 3(a)(4)
• Summary: This section defines a broker as any person engaged in the business of effecting transactions in securities for the account of others. Silent Rich does not engage in the negotiation, execution, or facilitation of securities transactions, thus not qualifying as a broker.

Broker-Dealer Registration Requirements

• Relevant Rule: SEC Rule 3a4-1
• Summary: This rule provides a “safe harbor” for individuals who do not regularly engage in securities transactions and thus do not need to register as broker-dealers. Silent Rich’s activities are limited to making introductions and sharing general information, which aligns with the safe harbor provisions.

Anti-Money Laundering (AML) Compliance

• Relevant Law: USA PATRIOT Act
• Summary: The USA PATRIOT Act requires financial institutions to establish anti-money laundering programs. While Silent Rich is not a financial institution, it adheres to AML best practices to ensure compliance and prevent illicit activities.

Regulation D and Private Placements

• Relevant Rule: Rule 506 of Regulation D
• Summary: This rule allows companies to raise capital through private placements without registering with the SEC, provided they do not engage in general solicitation or advertising. Silent Rich’s role in making introductions does not constitute solicitation or advertising of securities.

Finder’s Exception

• Relevant Guidance: SEC No-Action Letters (e.g., Paul Anka No-Action Letter, 1991)
• Summary: The SEC has provided guidance that individuals who act as “finders” and merely introduce potential investors to issuers without participating in negotiations or transactions may not need to register as brokers. Silent Rich’s connectors act within these guidelines, limiting their activities to introductions and general information sharing.

All members and clients of Silent Rich are encouraged to conduct thorough due diligence and seek appropriate professional advice before proceeding with any investment or business transactions. This includes consulting with legal, financial, and tax advisors to understand the implications and risks involved.

Our network of connectors operates within clearly defined boundaries to ensure compliance with SEC regulations. Connectors do not engage in the negotiation, execution, or facilitation of securities transactions. Their role is strictly limited to making introductions and sharing general information about potential opportunities.

Connectors associated with Silent Rich are prohibited from engaging in activities that involve the negotiation, execution, or facilitation of securities transactions. Any such activities must be conducted by licensed professionals who are authorized to handle securities transactions.

Silent Rich and its connectors provide referral and introduction services only. We facilitate connections between potential business partners, investors, and opportunities based on the information provided by our members. These introductions are made with the understanding that all parties will independently verify the suitability of any potential transaction.

Members of Silent Rich are responsible for ensuring that their participation in our network complies with all applicable laws and regulations. This includes obtaining any necessary licenses or approvals for their activities.

Silent Rich’s directory listings may include information on incentives offered to connectors. These incentives are designed to encourage connectors to seek and present valuable opportunities that align with the strategic goals of investment firms and businesses.

• Connectors may receive incentives, such as success fees, for successfully referring opportunities that lead to completed transactions.
• It is important to note that connectors who receive such incentives are not engaging in the negotiation, execution, or facilitation of securities transactions, which would require a broker-dealer license.
• Connectors who merely introduce potential investors to issuers and share general information are operating within the guidelines provided by the SEC and do not need to be licensed broker-dealers.
• However, any activities beyond introductions and general information sharing, such as negotiating or executing securities transactions, must be handled by licensed professionals.