Optec International Inc (OPTI)

[Olderandwiser]

Re: is Roger acting as an unregistered dealer?

I don’t think so, based on this detailed article:

“SEC Pursues Unregistered Dealers, Toxic Financing, Toxic Convertible Notes”

.https://www.securitieslawyer101.com/2021/unregistered-dealers-toxic-financings-toxic-lender-toxic-convertible-note/.

The section “What the SEC Says About Dealers” explains in detail who the SEC considers a dealer. Here’s an excerpt from that section:

“Individuals who think they may be acting as a dealer should ask themselves:
* Do you advertise or otherwise let others know that you are in the business of buying and selling securities?
* Do you do business with the public (either retail or institutional)?
* Do you make a market in, or quote prices for both purchases and sales of, one or more securities?
* Do you participate in a “selling group” or otherwise underwrite securities?
* Do you provide services to investors, such as handling money and securities, extending credit, or giving investment advice?
* Do you write derivatives contracts that are securities?”

Other opinions are welcome.