“Emerging Growth Companies” under Jumpstart Our Business Startups Act (2012)
…played or referenced” on a website. While “funding portals” are prohibited from compensating “employees, agents or other persons [presumably finders] on a success-fee basis. However, the owners could be earn profits based on success fees earned by the “funding portal” from listing information about Section 4(6)-exempt securities, including those of Emerging Growth Companies. Such “funding portals” could evolve into the equivalent of unregulated ex…