Operating a Reg CF funding portal means becoming a regulated intermediary, not building a website with a payments flow. Registration with the Commission and membership of FINRA, a supervisory structure, investor-education obligations and a compliance function are all conditions of doing the business at all.
We manage the pathway and build the framework. The registration and membership process, the written supervisory procedures and compliance manual, the investor-limit and onboarding mechanics, and the disclosure and record-keeping regime the platform has to operate continuously.
The engagement is for platforms, not issuers — organisations whose business is facilitating other companies’ raises. Where you intend to raise on your own behalf, the issuer route is a different and lighter engagement.
- You intend to operate a funding portal rather than raise on your own behalf.
- You are partway through registration or FINRA membership and need the framework completed.
- Your procedures exist but do not reflect how the platform actually operates.
- You need investor-limit enforcement and record-keeping built into the platform.
The regulator and FINRA, in that order
A funding portal registers with the Commission and must be a FINRA member. The two processes are linked and the sequencing matters, so the programme is planned around both from the start.
Procedures are the licence
A portal is examined on whether it follows its own written procedures. The compliance manual is not paperwork; it is the operating system of the business.
Investor limits run on the platform
Reg CF caps what an individual may invest, and the platform is responsible for enforcing it across all its offerings. That obligation sits in the onboarding and record-keeping design.
- Registration and FINRA membership pathway, with sequencing and timing
- Written supervisory procedures and compliance manual
- Investor-onboarding, education and investment-limit framework
- Issuer onboarding and offering-review process
- Books, records, reporting and examination-readiness programme
- Anti-fraud, communications and marketing-review procedures
- 01
Assess eligibility and model
What the platform will do, which activities registration permits, and whether the model fits the funding-portal or the broker-dealer route.
- 02
Build the procedures
The written supervisory procedures and compliance manual, drafted around the platform’s real operating process rather than a template.
- 03
File and pursue membership
Commission registration and FINRA membership managed together, with responses to requests for information handled as they arise.
- 04
Instrument the limits
Investor limits, education gating and record-keeping embedded in the onboarding and transaction flow.
- 05
Prepare to be examined
Books and records, reporting calendars and a supervisory review cycle so the platform is inspection-ready from its first day live.
Portal pathway read
A written assessment of the registration route, the model’s eligibility and what the framework will require.
Registration and framework build
Registration, membership and the full compliance framework delivered through to a live platform.
Procedures and examination readiness
A focused engagement to repair or complete the compliance framework of an operating portal.
- Companies that want to raise capital themselves — that is an issuer engagement, not a portal registration.
- Platforms intending to operate before registration and membership are in place, which is not a remediable position in this regime.
A funding portal is a limited-purpose intermediary permitted to facilitate Reg CF offerings and barred from certain activities — soliciting purchases, holding investor funds, offering investment advice. A broker-dealer can do more, and carries correspondingly heavier obligations and capital requirements. Which you need follows from what the platform must actually do.
The Commission registration and FINRA membership processes run to their own timelines and involve review of the application and the procedures. The main variable we control is the completeness of the framework submitted, which is why the procedures work is done properly rather than in parallel with filing and left thin.
A funding portal generally may not hold or handle investor funds; the money moves through an escrow arrangement with a qualified financial institution. That shapes the payment architecture fundamentally, so it has to be designed in rather than added later.
The platform has to have a reasonable basis for believing the issuer and the offering comply with the requirements, and must provide investor education and enforce limits. In practice that means a documented issuer-onboarding and offering-review process, not a self-certification.