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> "Affiliation" (usually) means something like a formal association, partnership, or close connection, not that you're just a customer

In securities, yes. In general use, not necessarily.




"Not necessarily" can apply to almost any use of language, but I feel like this kind of thing can commonly be interpreted as non-affiliated. In an analogous case, if you work for an organization that performs public elections, at least in my country, you can't be affiliated with a party, but your personal business (voting for them) isn't included. Being publicly connected with or being compensated by another entity would seem to me to present an arguable affiliation


> Being publicly connected with or being compensated by another entity would seem to me to present an arguable affiliation

It looks like it's a legitimate legal issue [1][2].

TL; DR It may make sense to explicitly clarify when you're using the term 'affiliate' as it is defined in 17 CFR § 230.601 / Rule 144 [3] versus "affiliate, including but not limited to []," or whatever.

[1] https://www.sackrosendin.com/blog/2017/03/landlord-loses-ove...

[2] https://casetext.com/case/iqbal-v-ziadeh-2

[3] https://www.law.cornell.edu/definitions/index.php?width=840&...




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