b'2.Mr. Anka was not previously involved in any securities offerings,3.He didnt handle or distribute offering materials,4.He did not handle investor funds,5.Nor did he provide any independent analysis of the performance of the company or securities, and6.He didnt participate in distribution of the securities post-sale.Thus, this is a very narrow exception, and in order for you to rely on it as a finder (or as an issuer that pays finders), you would have to meet identical conditions. This is still considered the on-point no action letter, when it comes to determining whether the finders exception applies.Rainieri Partners Cease-and-Desist Proceedings Below is a more recent case in which a finder claimed to rely on the Paul Anka no action letter, but in fact, did not meet these exact conditions and was found to have acted as an unlicensed broker:On March 8, 2013, The SEC issued administrative and cease-and-desist proceedingsagainstRainieriPartners,LLC(Rainieri),WilliamM. Stephens, an independent consultant who raised the money, and Donald W. Phillips, one of its managers, alleging that they were acting as an unlicensed securities broker in connection with the sale of interests in a fund offered by Rainieri.ThechargeagainstRainieri,StephensandPhillips,included allegations that:245'