Monday, July 12, 2021 As part of its continued enforcement focus on broker-dealer registration, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) recently settled an action with electronic order entry and management system Neovest, Inc. (“Neovest”) for engaging in “broker” activity and receiving “broker” compensation without being registered as a broker-dealer pursuant to Section 15(b) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). 1 Both the settlement and the strong dissent from SEC Commissioner Hester Peirce leave market participants without meaningful guidance on what constitutes “broker” activity requiring registration. Technology providers that perform functions that could easily be characterized as facilitating