ANCHOR MINT ADVISORY

Disclosures

Last Updated: April 24, 2026

About Anchor Mint Advisory

Anchor Mint Advisory is a boutique sell-side mergers and acquisitions advisory firm serving founders of privately held businesses generating between $200,000 and $100,000,000 in annual revenue. We provide advisory services in connection with business sales, ownership transfers, and related capital events.

Anchor Mint Advisory operates as a solo advisory practice. All client engagements are handled directly by the firm's founder. There are no junior advisors, associates, or delegated personnel involved in client work.

Regulatory Status

Unlicensed M&A Advisor

Anchor Mint Advisory is not registered as a broker-dealer with the U.S. Securities and Exchange Commission (SEC) and is not a member of the Financial Industry Regulatory Authority (FINRA). Anchor Mint Advisory does not hold a securities license and does not operate as a licensed investment bank.

Anchor Mint Advisory operates in reliance on the federal M&A Broker Exemption described below and limits its practice to transactions within the scope of that exemption.

The M&A Broker Exemption

On December 29, 2022, President Biden signed the Consolidated Appropriations Act of 2023 (H.R. 2617) into law. Included within that legislation was Section 501, titled "Small Business Mergers, Acquisitions, Sales and Brokerage Simplification," which added Section 15(b)(13) to the Securities Exchange Act of 1934.

This provision, commonly referred to as the M&A Broker Exemption, became effective on March 29, 2023. It established a federal statutory exemption from SEC broker-dealer registration for qualifying M&A brokers that facilitate change-of-control transactions involving certain privately held companies.

Prior to this exemption, M&A brokers operating without SEC registration relied on a no-action letter issued by the SEC's Division of Trading and Markets on January 31, 2014. That no-action letter was withdrawn on March 29, 2023, the same date the statutory exemption took effect.

What the Exemption Covers

To qualify under the M&A Broker Exemption, the broker must be engaged solely in facilitating securities transactions in connection with the transfer of ownership or control of an eligible privately held company. The exemption applies regardless of whether the broker represents the buyer or seller.

The exemption requires that upon completion of the transaction, the acquiring party will:

  • Control the company or the business conducted with its assets

  • Be actively involved in the management of that company or business

Additionally, if a buyer is offered securities of an issuer in exchange for the target company's assets or securities, the buyer must receive or have reasonable access to the issuer's most recent fiscal year-end financial statements, a balance sheet dated no more than 120 days before the offer date, and relevant information about the business and its management.

Eligible Privately Held Company Definition

The M&A Broker Exemption applies only to transactions involving an "eligible privately held company," defined as a company that, in the fiscal year immediately preceding the year in which the M&A broker's services are initially engaged, meets both of the following criteria:

  • No class of securities registered or required to be registered under Section 12 of the Exchange Act (i.e., the company is not publicly traded)

  • EBITDA of less than $25,000,000 and/or gross revenues of less than $250,000,000

The statute provides for inflation-based adjustments to these thresholds every five years from the date of enactment, beginning December 29, 2027.

What the Exemption Does Not Cover

The M&A Broker Exemption does not eliminate all regulatory obligations. The following restrictions apply to M&A brokers operating under the exemption:

  • The broker may not hold or handle client funds or securities

  • The broker may not provide financing to any party in the transaction

  • The broker may not represent both buyer and seller in the same transaction without informed written consent from both parties

  • The broker may not facilitate transactions involving shell companies, blank check companies, or companies with no established business operations

  • The exemption is federal in scope. State-level broker-dealer registration requirements may still apply depending on jurisdiction. Anchor Mint Advisory complies with applicable state-level requirements for transactions in which it is engaged.

The SEC's anti-fraud provisions under the Securities Exchange Act of 1934 continue to apply to all transactions, including those conducted under the M&A Broker Exemption.

Scope of Services

Anchor Mint Advisory provides sell-side M&A advisory services including transaction preparation, business positioning, buyer identification, process management, and negotiation support. Our services are advisory in nature.

Anchor Mint Advisory does not provide legal advice, tax advice, accounting services, or formal business valuations (valuations can be subjective subject matter, and there needs to be consensus between both sellers and buyers). Clients are advised to engage independent legal counsel, a licensed accountant, and other qualified professionals in connection with any transaction that our scope of services does not cover.

Nothing in any communication from Anchor Mint Advisory, including website content, tool outputs, or written materials, should be construed as a formal valuation opinion, fairness opinion, or investment recommendation. They exist solely for educational purposes.

Compensation

Anchor Mint Advisory is compensated through a combination of an upfront engagement fee, a monthly retainer, and a success fee payable upon close of a transaction. The upfront fee and retainer paid during the engagement are credited against the success fee at close.

Anchor Mint Advisory has a financial interest in the completion of transactions on behalf of clients. This creates an inherent incentive to facilitate a transaction. Prospective clients should take this into account when evaluating our advice and recommendations.

No Guarantee of Outcome

Anchor Mint Advisory makes no representation or guarantee that engaging our services will result in a completed transaction, a specific valuation, or any other particular outcome. M&A transactions are subject to market conditions, buyer availability, due diligence findings, financing contingencies, and other factors outside the control of any advisor.

Contact

For questions regarding these disclosures or the regulatory status of Anchor Mint Advisory, please contact:

Anchor Mint Advisory

Email: contact@anchor-mint.com

Website: www.anchor-mint.com

These disclosures are provided for informational purposes and do not constitute legal advice. Consult qualified legal counsel to ensure your advisory practice complies with all applicable federal and state requirements.