Crowdsurf has a limited role in screening the Issuers it permits to conduct Offerings on the Platform, however, Crowdsurf is required to:
Have a reasonable basis for believing an Issuer seeking to offer Securities on the Platform complies with the requirements of Regulation Crowdfunding; and
Have a reasonable basis for believing an Issuer has established means to keep accurate records of the holders of the Securities it would offer and sell through the Platform.
In addition, Crowdsurf will conduct off-platform due diligence and onboarding of potential Issuers, during which it will evaluate whether Issuers are a good fit to offer their Securities on the Platform. Crowdsurf’s initial due diligence procedures will include, at a minimum, conducting a background and securities enforcement regulatory history check on each Issuer whose Securities are to be offered on the Platform, and on each officer, director or beneficial owner of twenty percent (20%) or more of the Issuer’s outstanding voting equity securities, calculated on the basis of voting power. Crowdsurf may also conduct further due diligence on a case-by-case basis, based on the facts and circumstances of each Issuer and its proposed Offering.