EXHIBIT 14

Case 1:20-cv-21254-BB Document 47-15 Entered on FLSD Docket 07/02/2021 Page 1 of 7
From: Zack Eller

To: TradingAndMarkets; TMOIGLOG

Subject: Re: Oxford Center Broker Dealer License

Date: Friday, December 21, 2018 10:38:59 AM

Thank you for your help. I have reached out to our legal representation to figure out what we

would need.

Best,

Zack Eller

Business Advisory Manager

678.896.2491

843.414.5610

│ oxfordcenter.com

│ zack@oxfordcenter.com

65 Gadsden Street, Charleston, SC 29401

banner

On Thu, Dec 20, 2018 at 5:27 PM TradingAndMarkets <TradingAndMarkets@sec.gov> wrote:

Mr. Eller,

While we are able to provide informal guidance regarding the Exchange Act and the rules

adopted thereunder through this email box, we cannot provide legal advice. Applying the

regulations to a particular scenario approaches the realm of legal advice. Thus, we encourage

Case 1:20-cv-21254-BB Document 47-15 Entered on FLSD Docket 07/02/2021 Page 2 of 7
you to seek the counsel of an attorney familiar with the securities regulations and relevant case

law to determine whether your firm needs to register with the Commission as a broker based

on the specific activities it intends to engage in.

The staff of the Division of Trading and Markets has published some guidance on the

Commission’s website regarding the broker-dealer registration requirements here:

http://www.sec.gov/divisions/marketreg/bdguide.htm. This Guide to Broker-Dealer

Registration provides some basic information regarding the definition of “broker” and the

activities/factors the staff and the courts consider when determining whether a person fits that

definition (and would, therefore, need to register with the Commission).

As indicated in the Guide - to the extent a person engages in the business of effecting

transactions in securities for the account of others, that person would need to register with the

Commission. This is a fact-specific assessment that involves consideration of a number of

factors (which have been developed through SEC staff no action letters and case law). Factors

generally considered to determine whether a person would be considered to be “effecting

transactions in securities for the accounts of others” include, among other things, whether the

person is soliciting the purchase or sale of securities to others, is involved in the structuring or

negotiation of transactions, and receiving transaction-based compensation.

We hope this is helpful.

The Division of Trading and Markets

From: Zack Eller [mailto:zack@oxfordcenter.com] 

Sent: Thursday, December 20, 2018 2:23 PM

To: TradingAndMarkets; TMOIGLOG

Subject: Re: Oxford Center Broker Dealer License

I am not sure. We offer the following services to our companies:

Valuation

Sell-side advisory (all companies are privately held currently. we would be willing to

represent a public company if the opportunity presented itself)

IPO- we have not done an IPO in over 10 years from what I understand. We would like

to offer the services to members who are looking to IPO.

Capital raises.

What licenses/certifications would we need?

Case 1:20-cv-21254-BB Document 47-15 Entered on FLSD Docket 07/02/2021 Page 3 of 7
Best,

Zack Eller

Business Advisory Manager

678.896.2491

843.414.5610

│ oxfordcenter.com

│ zack@oxfordcenter.com

65 Gadsden Street, Charleston, SC 29401

Case 1:20-cv-21254-BB Document 47-15 Entered on FLSD Docket 07/02/2021 Page 4 of 7
On Thu, Dec 20, 2018 at 2:16 PM TradingAndMarkets <TradingAndMarkets@sec.gov>

wrote:

Mr. Zeller,

What license does your employee hold?

The Division of Trading and Markets

From: Zack Eller [mailto:zack@oxfordcenter.com] 

Sent: Thursday, December 20, 2018 12:47 PM

To: TradingAndMarkets; TMOIGLOG

Subject: Oxford Center Broker Dealer License

Good Afternoon,

Case 1:20-cv-21254-BB Document 47-15 Entered on FLSD Docket 07/02/2021 Page 5 of 7
My company, The Oxford Center for Entrepreneurs engages as an advisor for privately he’d

companies looking to sell their businesses. Occasionally, we will offer to underwrite and

IPO for a firm. We currently have an employee that holds a license. What are the processes

for transferring the license to another employee or getting a license for another employee?

Our current license holder will be leaving the firm in the next 2-3 years, possibly sooner.

My phone number is 678-896-2491. This is the best email to reach me.

Best,

Zack Eller

Business Advisory Manager

678.896.2491

843.414.5610

│ oxfordcenter.com

│ zack@oxfordcenter.com

65 Gadsden Street, Charleston, SC 29401

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