That other chap has erased my ability to be diplomatic...

That other chap has erased my ability to be diplomatic today.

You're right, TNR aren't running a FS company nor hopefully are they looking to so do. No argument.

And I'd be confident they haven't an AFSL. Again, no argument.

But that doesn't preclude them from placing shares directly.

Brokers are there to match buyers and sellers. Or better, to find buyers/placees.....hence the finder's fee.

But there is no requirement than a CR requires a company to use a broker or the like.....

And yes, familiar with how issuing to 708s avoids disclosure documents (that's why they created the carve out).