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If I find out anything, i'll post it here. It seems to be a grey area. I just asked an investment advisor friend of mine, and he was not sure since it's in the hedgefund arena.

Thanks for the response. It's an interesting angle to say that the investor is selling me the contact information. Especially if the contact is his friend that he has a previous relationship with. I'm not expecting the investor to solicit investments in my fund from people he doesn't know...

If I have an investor who is willing to refer some of his friends for a percentage of my performance fee, does investor need to be registered with some regulatory agency? Assume the business is based in New York. Also assume the investor is not actively soliciting or negotiating the deal...