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

To satisfy Rule 303(b), investors will need to verify their eligibility to participate in your offer.  By adding the Income Verification (Reg CF) step to your Investor Flow, the investor can do so directly in the platform.

To update the Investor Flow:

1. Select Offers from the left menu
2. Click in to one of your offers
3. Choose Investor Flow from the left
4. Click Add Investment Step
5. Choose Income Verification (Reg-CF) from the menu

Once an investor reaches this step in the flow, they will be guided through a questionnaire to verify that their income level is sufficient to make the current investment, taking into account all Reg CF investments they have made in the past 12 months.

To walk through an example, let's assume an investor intends to invest $2000.  They will be asked the following series of questions:

1. The investor is first asked if they have made any investments on any equity crowdfunding platforms in the past 12 months
   
   
   
2.  If No, their calculated Reg CF investment amount equals their current investment amount.
   • If Yes, they are asked to enter the amount, which is then added to the amount they are currently attempting to invest. e.g. If investing $2,000 today and they invested $3,000 in other Reg CF offerings in the last 12 months, their Reg CF investment amount for all subsequent calculations is $5,000.
     
     
     
3. If the calculated Reg CF investment amount is greater than $124,000, the user is not allowed to invest.
   
   
   
4. If the calculated Reg CF investment amount is less than $2,500, they are allowed to proceed, as there are no other income restrictions that would prohibit the investment.
   
   
   
   
5. If the calculated Reg CF investment amount is between $2,500 and $6,200, the 5% rule catches all other restrictions since $6,200 is 5% of the income / net worth breakpoint of   $124,000. The user is then asked if their annual income and net worth are both greater than the Reg CF investment amount x 20 (amount is no more than 5% of income / net worth).
   
   
   
6. If the calculated Reg CF investment amount is between $6,200 and $12,400, they are not eligible for the 5% rule, and must have an income and net worth both greater than the fixed breakpoint of $124,000 (since the amount is $12,400 or under, the 10% rule does not come into play).
   
   
   
7. If the calculated Reg CF investment amount is over $12,400, the 10% rule applies, and the user is asked if their annual income and net worth are both greater than the Reg CF investment amount x 10 (the amount is no more than 10% of income / net worth).