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I suggest anyone operating outside the US and promoting US Sponsors have their stuff together, if, for no other reason, to cover your ass. Regardless what the outcome of this new amendment happens to be, I see Sponsors becoming a lot more strict on this requirement with their affiliates. Why? Because when all is said and done, it is the Sponsor who will face the tougher penalty as the primary producer. And, if the affiliate is outside the US, you better believe they'll be even more motivated to go after and stick it to the US based Sponsor.
Bottomline for all (US based or not): Get an attorney, get compliant and stay that way.
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