EPISODE · Jun 3, 2026 · 8 MIN
Finder’s Fees in Regulation D Private Placements: Who Needs the License?
from Syndication Attorney Field Notes with Tilden Moschetti · host Tilden Moschetti
=Short legal field notes from syndication attorney Tilden Moschetti for sponsors raising capital through Regulation D offerings, private placements, syndications, and investment funds. In this episode, we address a common sponsor question: do you need a license to pay finder’s fees for investor introductions? The reality is that there is no payer’s license. Instead, the focus is on whether the recipient of transaction-based compensation is properly registered. Tilden explains how success-based pay in a Regulation D private placement may raise broker-dealer registration issues, why a real estate license is not a substitute, and the steps to verify registered placement agents before any money changes hands.Also see: No License to Pay Finder’s Fees in a Reg D Offering at https://www.moschettilaw.com/finder-fees-reg-d
What this episode covers
In this field note, syndication attorney Tilden Moschetti explains why paying finder’s fees for investor introductions in a Regulation D private placement can move a capital raise into broker-dealer registration territory.
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Finder’s Fees in Regulation D Private Placements: Who Needs the License?
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