• What is the difference between a referral agent and a finder?

In questions 10 and 11 of the General Section of the Risk Assessment Questionnaire, the OSC references referral arrangements and finder arrangements. We have received a number of enquiries regarding the difference, if any, between these two arrangements. There is, in fact, a subtle yet important distinction between referral and finder arrangements. While referral and finder arrangements refer to similar activities, that is “referring” an investor to a registrant or issuer and “finding” an investor for a registrant or issuer, the distinction lies in how active a role the referral agent and finder play, and how close each comes to registerable activity. While a referral agent could simply provide the name of a potential client or clients to an issuer or registrant, a finder is generally seen as playing a more active role in soliciting clients, and thus more often viewed as engaging in registerable activity as a dealer.