SEC Division of Trading and Markets no-action letter: Welton Street Investments, LLC

The SEC staff will not recommend enforcement action under Section 15(a) of the Securities Exchange Act of 1934 against real estate brokerage firms if their associated persons are dual-registered with Welton Street Investments, LLC (WSI), provided the firms do not register as broker-dealers. This relief applies when WSI dual-registered persons pay a flat periodic desk fee or a real estate percentage fee to unregistered real estate firms, ensuring the fees are not tied to securities transaction volume or commissions. The arrangement requires strict operational separation, including independent offices, separate business cards, and prohibitions on the real estate firm engaging in securities activities, handling funds, or advertising TIC Securities. WSI retains exclusive supervisory control and must maintain records of these agreements for at least three years.

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SKADDEN,ARPS, SLATE, MEAGHER 6( FLOMLLP
1440 NEW YORK AVENUE, N.W,
FIRMIAFFILIATE OFFICES WASHINGTON, D.C. 20005-2 1 1 I ...
BOSTON
CHICAGO
HOUSTON
LOS ANGELES
NEW YORK
PAL0 ALTO DIRECT DIAL SAN FRANCISCO 202-37 1-72 16 Wl LMINGTON DIRECT FAX 202-661-8286 BElJlNG EMAIL ADDRESS BRUSSELS SUZ.ANNE.ROTHWELL@SKADDEN FRANKFURT COM HONG KONG

LONDON

MOSCOW

MUNICH

PARIS

SINGAPORE

SYDNEY

TOKYO

June 26,2006 TORONTO
VIENNA
Catherine McGuire, Chief Counsel

Division of Market Regulation

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