How to set up a demo Reg CF deal for the FINRA audit/interview? (Crowdfunding, Reg-CF, Audit, FINRA)

Modified on Wed, Mar 30, 2022 at 10:01 AM

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The purpose of FINRA's demo of a Reg CF deal is to verify the entire Reg CF transaction flow is compliant.

Here are some key items that must be setup in your platform:

1. [ Rule 303(a)(4) ] You need to make offer public and turn off 'Require Sign In to View Offers' in Platform => Settings => Features

Article: How can I allow investors to view deals without signing up?

2. [ Rule 302(a)(1) ] You need to have the user agree to the delivery of all communication electronically when they sign up. This can be done by adding an Acknowledge field type (with the appropriate message) to your forms and marking it as 'Add to Account Setup Form'.

Sample message: "By checking this box, I give my consent to receiving electronic delivery of information from the Portal. I understand that the Portal will email me my transaction receipts and other necessary information through the email I provided, which I can change anytime."

Article: How can I add a field for consenting to electronic communications on sign up?

3. [ Rule 302(a)(2) ] You need to update the default email verification email to include a welcome with links to education material. This can be found under Engagement => Email => Platform Emails => click Account => click New Sign Up

Article: Do you have a sample Welcome Email for Reg CF?

Article: [Rule 302(b)] Where can I find Reg CF education material?

4. [ Rule 303(c) ] Turn offer Q&A feature/tab on

Article: How do I add a message board chat room function where investors can publicly ask the issuer questions regarding the offering?

5. [ Rule 303(b) ]Need to add Reg CF Income Verification step to your Investor Flow. When adding the step, you'll notice that you must include links to education material and the issuer's filed Form C

For demo purposes, you can use any links/URL and any company's FORM C.

Adding this step does two things:

a. [ Rule 303(b)(1) ] Adds the Income Verification questionnaire

Article: How investments made outside of your platform will be considered in the calculation of investor qualifications and crowdfunding limits as noted in Reg CF Rule 303(b)?

b. [ Rule 303(b)(2) ] Embeds your education/form C links into the built-in disclosures that appear on the payment screen

[ Rule 303(d),(f) ] "Notice of investment commitment": How to customize messages on platform operational/transactional emails?

[ Rule 302(c),(d) ] "Promoter's Compensation disclosure": Where do I update disclosures/disclaimers (e.g. policies, terms & condition, disclosure) ?

REF: What is your disaster recovery process?

#Reg CF, demo, flow, transaction, requirement, interview