Who is on the team for a Reg CF or Reg A+ raise, and what to ask each of them

A Reg CF or Reg A+ raise is run by six to nine outside parties, most of whom the company has never hired before: securities counsel, an accountant, a funding portal or broker-dealer, an escrow agent, a transfer agent, a marketing partner, creative production, investor support, and the tech that ties them together. Some are required by the rules, some are choices, and increasingly several of them arrive bundled under one contract. This post is the roster, the order they enter, and the questions that separate a good hire from a costly one. It names no platforms or agencies, because the market changes and the questions do not.

At a glance

Securities counsel

Counsel drafts the Form C or the Form 1-A, sets the boundary of what the company may say and when, and reviews the marketing before it runs. On a Reg A+ they also carry the SEC comment process through to qualification. Nothing about the raise should be scheduled before counsel is engaged, because everything downstream sits inside the lines they draw.

Ask: how many offerings have you taken through this exemption, and this tier. Who on your team reviews creative, and what is the turnaround in launch week. Do you know the intermediary's compliance team, and have you worked a raise with them before.

The accountant

Reg CF ties the financial statement requirement to the raise size, from officer-certified statements at the bottom through reviewed to audited; Tier 2 Reg A+ requires audited financials and the ongoing reports after. The accountant's calendar is one of the two long poles in the timeline, and a change to the target can change the tier and the work. The limits and tiers are in reg-cf-limits-explained.

Ask: have you done reviewed or audited work for this exemption before, and under the standards it requires. What is the calendar to a deliverable, and what pushes it. If the target moves and the tier moves with it, what happens to the engagement.

The funding portal or broker-dealer

A Reg CF offering must run through one registered intermediary, either a funding portal or a broker-dealer, and there is no way around that. A Reg A+ offering does not require one, but most engage a broker-dealer for the investor onboarding, the state notice filings, and the checkout. The intermediary runs the offering page, enforces the investor limits, coordinates escrow, and reports progress. Its compliance team is the first review your marketing meets, because its own license is on the line.

Ask: what are the fees, and how are they structured across cash, equity, and success. How large is your investor base, how many of them invest more than once, and are those investors reachable by me after the raise or only by you. What data do I get during and after the offering, and in what form. What will your compliance team not let me say, and how fast do they review. For how to weigh one against another, see highest-performing-funding-platforms-2026.

The escrow agent and the transfer agent

Two parties most issuers meet only on the closing documents. The escrow agent holds investor funds until a closing and returns them if the target is missed. The transfer agent keeps the record of who owns what after the raise, handles transfers, and is who investors call about their shares in year two. Both are often chosen by the intermediary rather than the issuer.

The transfer agent is closer to required than it looks. Both exemptions rely on a conditional exemption from Exchange Act registration once a company has many holders of record, and one condition of each is that the company has engaged a transfer agent registered with the SEC. Skipping it is a way to acquire a registration obligation you did not plan for. Counsel will confirm which conditions apply to your company.

Ask: who chose you, and what do you charge, per event and per year. How long does a close take from the day the target is met. What does an investor experience when they ask about their shares, and who answers.

The marketing partner

No rule requires one, and it is the difference between a raise and a filing. The marketing partner builds the audience, tests and produces the creative, runs the media, writes the email, and owns the funnel from ad to completed investment. Everyone else on this list is executing a defined process; this is the role where the outcome is not defined until the work is done. What to look for is covered in agencies-guessing-at-investor-targeting, and the reasons to be careful about the version sold by the platform are in funding-platform-ad-services-mistake.

Ask: have you run a raise that hit its target, and can you describe the numbers. What is the one number you optimize, and how do you track it through the intermediary's checkout. Who owns the ad accounts, the pixels, the audiences, and the list when the engagement ends.

Video and creative production

The pitch video, the offering page assets, and the ad variations. Sometimes inside the marketing partner, often a separate shop. The work is not just production quality; it is turnaround, because every asset goes through counsel and the intermediary before it runs, and a compliance edit that takes a week to cut is a week of launch momentum lost.

Ask: who holds the rights to the footage and the edits. How many variations are in the scope, because the raise needs several, not one. How fast can you turn a compliance change.

Investor relations and support

Someone answers the inbox, moderates the comment sections, sends the updates, and fields the question every investor asks twice. During launch week that is a full-time job, and it is also a compliance surface, because an answer in a comment thread is a statement about the offering. What to hide, answer, and never say is in moderating-comments-during-a-raise.

Ask: who holds the keys during launch week, and what is the response time. What goes to counsel before it goes out, and what does not need to. Who owns the update cadence after the raise closes.

The tech layer

Landing pages, the reservation page for testing the waters, tracking that carries from the ad through the intermediary's domain to the confirmation, the CRM, the email platform. Unglamorous, and the place where the most expensive mistakes hide: a raise that spends its first week of media before discovering that attribution stops at the portal's front door has no idea what is working.

Ask: is attribution verified end to end, with live events, before the first dollar of media. Who owns the domain, the pages, and the data. What happens to all of it when the raise ends.

When several of them come under one roof

Many platforms, and some agencies, now offer several of these roles in one contract: the intermediary plus the marketing, or marketing plus video plus tech, or document preparation alongside the portal. Bundling is not wrong. For a first raise it can be the simplest path, with one calendar and one point of contact. What matters is knowing exactly which roles are inside the bundle and what that changes, because the questions above do not go away when the roles are combined; they get harder to ask.

Ask, before signing:

• Which of these roles does this contract actually cover, and which are still mine to hire? A bundle that includes the portal and the media may still leave counsel, the accountant, the transfer agent, and support to you, and the gap is where the calendar breaks.
• Where does one party's interest conflict with mine? An intermediary that also sells the media is paid whether or not the media performs. A bundle that owns the tracking grades its own work.
• If the bundled marketing underperforms, can I bring in someone else without leaving the platform? Mid-raise is the worst time to discover the answer is no.
• Who owns what when it ends? The ad accounts, the audiences, the list, the creative, the tracking, the domain. In a bundle the default answer is often the bundle.
• Is the price a price per service, or one fee that hides which parts are worth anything? Ask for it broken out, even if you buy it whole.
• Who inside the bundle reviews the marketing for compliance, and is that the same person selling it? Review and sales should not share a desk.

A bundle that answers all six cleanly is a reasonable choice. A bundle that cannot is a set of separate hires you have not yet made, at a single price.

The order they enter

Counsel and the accountant first, months out, because their calendars are the long poles. The intermediary next, because its choice constrains the checkout, the escrow, often the transfer agent, and what the marketing may say. The marketing partner before testing the waters opens, not after qualification, because the window before the raise is where the audience gets built; that playbook is in testing-the-waters-playbook. Video and tech during that window, so the creative is tested and the tracking verified before there is a live total to protect. Support before launch week. The transfer agent before the first close. On a Reg A+, the whole sequence runs against a qualification date nobody can set precisely, which is covered in what-is-reg-a-plus.

Where the handoffs break

Every party on this list does its own piece well and assumes somebody else is watching the whole. Three breaks account for most of the damage.

Creative waiting on review in launch week. Counsel, the intermediary, and the marketing partner each assume the other has the turnaround. Agree the review path and the response time before the first asset exists.

Tracking nobody verified. The tech layer built it, the marketing partner assumed it, the intermediary's domain broke it. Test with live events, all the way to a confirmed investment, before media spend starts.

A closing calendar nobody owns. The escrow agent, the intermediary, the transfer agent, and counsel each hold a piece of the close. Name the person inside the company who owns the calendar across all of them, before anything else is scheduled.

That last point is the whole post in one line. The team is hired from outside; the accountability cannot be. For who regulates each of these parties, and who does not, see who-regulates-equity-crowdfunding.

This is general information about the parties involved in a securities offering, not legal advice. Which roles your offering requires, and on what terms, are questions for your own securities counsel and your intermediary.

FAQ

Who do you need to hire for a Reg CF offering?

At minimum securities counsel, an accountant at the level the raise size requires, and one registered intermediary, either a funding portal or a broker-dealer, which the rules require. The intermediary usually arranges escrow. A registered transfer agent is a condition of the exemption from Exchange Act registration most issuers rely on. Marketing, creative, support, and tech are not required by any rule and are where the outcome is decided.

Who do you need to hire for a Reg A+ offering?

Securities counsel to draft the Form 1-A and carry the SEC review, an auditor for Tier 2, and usually a broker-dealer for onboarding, state notice filings, and checkout, though the rules do not require one. A registered transfer agent is a condition of the Tier 2 exemption from Exchange Act registration. The marketing, creative, support, and tech roles are choices, and a Tier 2 raise is large enough that they are usually a full campaign team.

Do you need a broker-dealer for a Reg A+ offering?

The rules do not require one. Most Reg A+ issuers engage a broker-dealer anyway, for investor onboarding, the state notice filings, and the checkout, and some intermediaries will not host an offering without one. Your counsel can advise on whether your offering should have one.

Do you need a transfer agent for a crowdfunding raise?

In practice, yes. Both Reg CF and Tier 2 Reg A+ issuers rely on a conditional exemption from Exchange Act registration once they have many holders of record, and each exemption requires the company to have engaged a transfer agent registered with the SEC. The transfer agent also keeps the ownership record and handles investor questions about shares after the raise.

Should you use your funding platform's marketing services?

Sometimes, and only after asking which roles the bundle covers, where the platform's interest conflicts with yours, whether you can bring in another marketer without leaving the platform, who owns the accounts and data afterward, and whether the compliance reviewer and the seller are the same person. A bundle that answers those cleanly can be the simplest path for a first raise.

How much does the team for a raise cost?

It depends on the exemption, the tier, the raise size, and which roles are bundled, and most of it is spent before the first dollar comes in: counsel, the accountant, and the intermediary's setup are front loaded, and the marketing runs through the campaign. Ask each party for its price broken out, even inside a bundle, so you know what each piece is worth.