CrowdCheck Blog

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

We keep hearing this question.  To be honest, it’s not clear why a crowdfunding issuer would want to have to deal with the recordkeeping for what could be thousands of investors (and even if the issuer uses a Reg CF SPV, that itself is an issuer whose many shareholders have to be wrangled). But are you absolutely required to have one? Let’s look first at Rule 301 of Regulation CF. This (titled “Measures to reduce risk of fraud”) requires that the intermediary in a Reg CF offering have a…

That picture probably isn’t an emoji, because emojis aren’t detailed enough for a message of that size. But they do convey some information, which is why, we assume, people use them. And since emojis are capable of conveying information, they are also capable of conveying misinformation, even misleading information that violates the securities laws. For some time, we’ve been discouraging our clients from using emojis or other images that could be misleading. Rocketships and unicorns have long…

That picture probably isn’t an emoji, because emojis aren’t detailed enough for a message of that size. But they do convey some information, which is why, we assume, people use them. And since emojis are capable of conveying information, they are also capable of conveying misinformation, even misleading information that violates the securities laws. For some time, we’ve been discouraging our clients from using emojis or other images that could be misleading. Rocketships and unicorns have long…

That picture probably isn’t an emoji, because emojis aren’t detailed enough for a message of that size. But they do convey some information, which is why, we assume, people use them. And since emojis are capable of conveying information, they are also capable of conveying misinformation, even misleading information that violates the securities laws. For some time, we’ve been discouraging our clients from using emojis or other images that could be misleading. Rocketships and unicorns have long…