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Who Qualifies as an Agent

Overview

  • Broker-dealers are financial institutions that help customers buy and sell securities (covered in the previous section).
  • Agents are natural persons (human beings) who work for broker-dealers.
  • Agents can also work for issuers.

🔑 Definitions

TermDefinition (statutory, word-for-word)Example
Agent> Any individual who represents a broker-dealer or issuer in effecting or attempting to effect purchases or sales of securitiesA registered representative you reach when you call a broker-dealer for help placing a stock trade.
Issuer> Any person who issues or proposes to issue any securityMcDonald’s is the issuer of McDonald’s common stock (MCD).

Agent — word-for-word:

Any individual who represents a broker-dealer or issuer in effecting or attempting to effect purchases or sales of securities

Issuer — word-for-word:

Any person who issues or proposes to issue any security

The agent definition covers “effecting OR attempting to effect” — the attempt alone is enough; a completed transaction is not required.

An agent must be an individual / natural person (human being). Broker-dealers themselves are firms (entities), not agents. Do not confuse the firm with the human being representing it.

How customers may interact with a broker-dealer

  • In many cases, customers can interact with a broker-dealer without ever speaking to an agent — especially with modern digital platforms.
  • Example: young investors with Robinhood accounts. Many customers may never have a human-to-human interaction.
  • ⚠️ In those situations, the customer is working directly with the broker-dealer, with no agent involved.
  • Agents are still an important part of the industry:
    • Technology can’t cover every situation.
    • Many investors prefer working with a person when placing trades or asking questions.
    • If you call a broker-dealer for help with a stock trade, you’ll typically be connected with one of its registered agents.

Common roles and responsibilities of agents

Role / responsibilityExample given by the text
General brokerage customer service
Transaction supportExplaining what a limit or stop order is
Transaction processingSubmitting a stock trade for a customer
Relationship managementPoint of contact for a broker-dealer’s most profitable clients
Back office supportManaging customer files
Supervision of other agentsActing as a manager for a team of agents

Agents and issuers

  • Agents are most commonly associated with broker-dealers, but some issuer employees may also be registered as agents.

What an issuer is

Issuers are organizations that raise capital (money) by selling securities tied to their organizations.

IssuerSecurity issued
McDonald’sMcDonald’s common stock (MCD)
FidelityFidelity Total Bond Fund (FTBFX)
The US Government (technically the US Department of Treasury)Treasury bonds

Why issuers usually do NOT use their own agents

  • Most of the time, issuers “farm out” the responsibility of selling their securities.
  • Example: AirBnB hired Morgan Stanley and Goldman Sachs as co-lead underwriters for their initial public offering (IPO) in December 2020.
  • As a hospitality-based business, it wouldn’t make much sense for AirBnB to build an entire finance department solely to sell its securities:
    • That would be expensive.
    • After the IPO the company might not need that department for a long time.
    • If the company didn’t plan to sell another security for some time, the department could be shut down, creating major costs and disruption.
  • 📌 That’s why nearly every issuer, sometimes even including financial institutions, hires a third party to sell its securities.

When issuer employees DO become agents

  • Some issuers do have their own employees sell their securities.
  • 🔑 When those employees represent (work for) the issuer in securities transactions, they must register as agents.
  • Example: imagine AirBnB created an internal department responsible for selling its stock to the public. In that case, every employee engaging investors in those sales efforts would be required to register as an agent.

Who IS and who IS NOT an agent (per this chapter)

SituationAgent?Basis in the text
Natural person representing a broker-dealer in effecting/attempting to effect securities purchases or sales✅ IS an agentMatches the definition directly
Natural person representing an issuer in effecting/attempting to effect securities purchases or sales✅ IS an agent“Agents can also work for issuers”; issuer employees engaging investors in sales efforts “would be required to register as an agent”
Issuer employee engaging investors in the issuer’s own sales efforts (e.g., hypothetical AirBnB internal sales department)✅ IS an agentText states registration is required
The broker-dealer firm itself❌ NOT an agentAgents are natural persons; the broker-dealer is the financial institution
The issuer organization itself❌ NOT an agentThe issuer is the entity that “issues or proposes to issue any security”
Customer trading directly through a digital platform with no human involved❌ No agent involved“the customer is working directly with the broker-dealer, with no agent involved”

Note: this chapter defines who is an agent. The related exempt vs. excluded distinction is covered in the separate “Exempt & excluded” section of Definitions — keep the two straight: an exclusion means the person never falls within the definition at all, while an exemption means the person meets the definition but is relieved from registration.

Key points

Agent

  • Natural person (human being) representing broker-dealers and issuers
  • Effects securities transactions for customers

More from Definitions: Persons · Exempt & excluded · Issuers & securities · Broker-dealers · Investment advisers

Sources

Primary/official references for the material in this chapter. Every link was fetched and returned HTTP 200 on 2026-08-15.

#SourcePublisher
1Uniform Securities Act 1956 with NASAA updates — the tested statute NASAA
2Exchange Act 1934 — broker, dealer, exchange definitions Cornell LII (15 U.S.C. 78c)
3Model rule — dishonest/unethical practices of BDs and agents NASAA
4Achievable Series 65 — chapter 4.2.5 Achievable (course text)
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