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United States JOBS ACT Commission
Guidance Documents
NEWBIZECO
The New Business Ecosystem NBE (headed up by Vantage Advisors) is the Veteran's Business Coalition partner tasked with developing and coordinating new business sales opportunities on behalf of financial professionals who agree to support Veteran Owned Businesses and their affiliates in accordance with NBE methodologies. These selected financial professionals must agree to operate in compliance with the spirit of the Jobs Act and the obligations contained within the Regulation B.I. The VBC administers the following compliance enforcement guidance process in order to ensure that financial professionals within the United States operate in such a way to greatly increase their company's revenues in a efficient an compliant fashion while a the same time addressing the needs of our nation's veterans.
1
INTRODUCTION
TO THE VBC
Field representatives of the Veteran's Business Coalition (VBC) will be approaching members of the financial community to interview and discuss some of the finer points with respect to the Investment Company Act of 1940, the Investment Advisor Act of 1940, the JOBS Act, Regulation BI, along with other related rules and legislation.
FISCAL
RESPONSIBILITY
FOLLOW-UP
2
During a second discussion the (VBC) representative will illustrate the rewards and new business that can generated through the utilization of methodologies outlined in the New Business Ecosystem along with the benefits that can be generated for veterans and other affiliated parties
3
NON-COMPLIANCE
WARNING
In the event there is not an affirmative response from the financial professional being interviewed that same financial professional will have an opportunity to present their own plan that meets VBC requirements within 21 days from the receipt of request from VBC Administration. The VBC requirements state any plan submitted by a financial professional seeking to initiate their own program must meet four criteria, those being, 1/ significantly increases their company's revenues on a rapid and on going basis 2/ help stimulate job creation and capital formation on a continuous basis 3/ have a on going positive economic impact on veterans 4/ Adhere to Regulation BI and other relevant compliance rules and directives.
4
72 HOUR
INVESTIGATION
WARNING
If 20 days elapse with out a satisfactory response from the financial professional being interviewed the VBC Administration will send the financial professional a Notice of Non Compliance. At that time a file will be opened an referred to the VBC Chief Liaison Officer for review and assessment. If circumstances merit the liaison officer will refer the file to VBC Governance Board. The VBC Governance Board powers will be among but not limited to mediation, investigation, sanctions, boycotts, initiation of government agency enforcement actions, and Re-Education Program admissions oversight.
5
necessary
COMPLIANCE
MEASURES
The VBC Governance Board can take up to 30 days to make a determination as to if any further action will be taken with respect to the non responsive professional being interviewed. After the Governance Board renders it's decision if the professional dis-agrees or feels as if they have been handled unfairly they will be entitled to attend a hearing with the Governance Board to state their case and be questioned under oath.
The VBC Governance Board can take up to 15 days to grant any hearing request submitted by a financial professional.
No more than 21 days after the hearing is held a decision by the Governance Board will be rendered with respect to any non responsive financial professionals.
There is no official appeal process. All verdicts rendered by the VBC Governance Board are final and can only be rescinded by a majority vote of the Governance Board members themselves. Any appeals to be heard or considered will be solely at the discretion of the Governance Board chairperson.
RE-EDUCATION
Program
Admission
6
If at any time a financial professional admits themselves into the VBC Re-Education Program all pending actions if any against that financial professional and or their organization will be suspended subject to Re-Education Program completion and compliance.