Answers

• Roger Rhodes Aug 04, 2012 07:55 pm GMT

  Looking good

• Dante Hamilton Aug 05, 2012 04:34 pm GMT

  I would think this may skirt some FINRA issues somehow and I would think its like a finders fee. You may need to have a Series 7, 63 or something like a certificate to do this and get away without violating Blue Sky Laws somehow. Just my take, but I am not a lawyer or securities expert.

• Howard Orloff Aug 06, 2012 03:23 am GMT

  Any ideas how affiliate programs currently work with banks and financial institutions? Would that jbe a flat cost per click?
  
  

• Arctic Island Aug 06, 2012 06:20 pm GMT

  Very simple answer here - "no, you cannot create an affiliate program and rev-share like you can with other web businesses."

• Howard Orloff Aug 06, 2012 11:42 pm GMT

  Based on? What leads you to this "very simple" answer?
  Just curious on why your sure about this? Seems like FOREX sites participate in affiliate programs.

• Randy Shipley Aug 08, 2012 02:30 pm GMT

  To state flatly as fact that you cannot create an affiliate program or rev-share now, without knowing rules and regs, is not a proper answer.
  
  In all probability there will be programs that an intermediary can do affiliate with - example Quickbooks or possibly BizFilings. You may also get affiliate fees from other sites with services or products that do not in essence show a preference, and that you do not feature in any way on the issuer's information.
  
  By that I mean you will not be able to get affiliate fee from incubators, business planning systems, valuation companies, accountants - that you then "feature" in some way - this may be viewed as a "recommendation" for issuers using your affiliate partner, implying that the issuer has a better chance of success and ultimately increase in valuation if they use the affiliate. These types of affiliations could cause significant exposure to the intermediary. This can apply to non-affiliates as well - example if you as intermediary allow a search or feature of issuers that have done their business plan with SCORE or BizPlan Pro you may actually be recommending that these issuers have a lower opportunity to fail - in essence you are recommending that issuers and investors alike favor these types of affiliation.
  
  I also do not believe you will be able to have an affiliate that is paid based upon bringing investors to the issuer and the affiliate receiving a percentage of the investors' investment amount.
  
  

• Oliver Neumann Aug 30, 2012 04:15 pm GMT

  Dear Randy,
  
  I believe this is an interesting topic. I think that crowd funding and especially crowd investing platforms will get into an liquidity problem. Only if there will be sufficient liquidity on each platform the concept will survive. In order to achieve this platform will need to establish affiliation programs that pay a rev. share per forwarded investor.
  
  The question to you guys is, do you think that crowd sourcing platform will develop affiliation programs in the near future.
  
  I am looking forward to your ideas.
  
  Cheers
  Oliver

• Sen Gupta Jan 08, 2013 10:48 pm GMT

  As it looks now , it appears affiliates will be out at least as far as intermediaries are concerned: Section 4A(a) 10. which says "Not compensate promoters, finders, or lead generators for providing the intermediary with the personal information of any potential investor;". But issuers might be allowed with adequate disclosure, under Section 4A(b) 3. "Not compensate or commit to compensate any person to promote its offerings through communications channels provided by a broker or funding portal without taking steps provided by the SEC to ensure that the compensation associated with any promotion is adequately disclosed;" Source: Kyle Hulten on April 2, 2012 from a Google search.
  
  Also Randy Shipley's points are well taken. I somehow can't connect the liquidity issue with Affiliate Programs - some elaboration might be helpful.
  
  Cheers