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AdministratorApril 22, 2020 at 11:03 am
Orett – also, realizing that you are asking about giving a specific amount ($2,200, which happens to be the Reg CF minimum 12-month investor limit) to investors, another question to ask is – what is your personal 12-month Reg CF investment limit, and does this exceed that amount?
See our Reg CF limit calculator here.
If your question is more around the legality of trying to circumvent the Reg CF investment limits for each investor, then you also need to take your Reg CF investment limitations under consideration. Reg CF investment limits are designed to protect investors – so technically, while you may be able to do this and not have anyone (such as the SEC) easily notice, it could potentially get the company and/or the funding portal in trouble for violating Reg CF rules.
If you did this, opened up the funding portal and/or issuer to liability and they somehow went bust as a result, there is the possibility that you could then be sued for fraud in some manner by these parties and other investors for being the cause of the whole situation.
Again, Reg CF limitations are something currently under review by the SEC and may be changing; but we’d always recommend that you comply with the limits and regulations as they are today.