Foreign Chaperoning services are overseen by the Compliance and Legal teams at Old City, please direct all Foreign Chaperoning inquiries to Becky Spiess at becky@oldcitycapital.com
General Considerations
Old City provides Foreign Chaperoning services (“Chaperoning”) to Foreign Broker-Dealers and their Associated Persons, as such terms are defined in Rule 15a-6. Most foreign businesses and individuals that raise capital for private funds or direct deals, and are registered for such activity or operate under an exemption in their home jurisdiction, meet that definition.
Under the Chaperoning arrangement, Foreign BDs may present private placements to Major Institutional Investors (firms with over $100m AUM) in the U.S. (“MIIs”) with which they have a pre-existing relationship.
Information submitted to Old City in connection with its diligence and monitoring of the Chaperoning activity will be reviewed only by the firm’s Compliance and legal departments and will be kept confidential. All submissions of due diligence information and ongoing reporting are via secure system provided by Old City.
Due Diligence
Old City will collect diligence information about the Foreign BD and its relevant Associated Persons at the time that the Chaperoning relationship begins.
For each private placement offering that a Foreign BD wishes to promote under the Chaperoning arrangement, Old City will collect due diligence information relating to that offering.
Ongoing Reporting
Old City utilizes digital reporting tools for Chaperoned Foreign BDs to inform Old City of their communications with MIIs and notify Old City of any subscriptions by such investors in the offerings represented by the Foreign BD.
These tools allow for Foreign BDs to keep Old City apprised of any business visits by its Associated Persons to the United States. Visits to the U.S. for solicitation of MIIs may not exceed 30 days per year