WASHINGTON, D.C. - August 14, 2026 - (KOREWIRE) - The Crowdfunding Professional Association (CfPA) today released an industry best practice encouraging crowdfunding intermediaries to proactively remind companies of annual reporting obligations under Regulation Crowdfunding (Reg CF).
As part of this initiative, the CfPA recommends that Reg CF intermediaries – funding portals and broker-dealers that facilitate Reg CF offerings – incorporate language through which companies acknowledge these ongoing reporting obligations in their client agreements. To support intermediaries and to ensure consistency across the industry, the CfPA has developed a standardized acknowledgment template that intermediaries can adopt, subject to review by their legal and compliance advisors. This best practice is designed to help Reg CF companies better understand their ongoing reporting obligations – including the requirement to file annual reports on Form C-AR until their reporting obligation is terminated under SEC rules – before they begin their offering under Reg CF.
By establishing clear expectations at the outset of the company-intermediary relationship, the CfPA believes the industry can reduce inadvertent Reg CF company noncompliance, promote greater investor transparency, and strengthen confidence in the regulated investment crowdfunding marketplace.
DealMaker Securities, Invown and BioTech Funding Portal are among the initial crowdfunding intermediaries already adopting the CfPA best practice. Their early adoption demonstrates industry willingness to adopt a consistent, scalable approach to helping companies understand their ongoing Reg CF reporting responsibilities.
Under Reg CF, a company that has sold securities, referred to under the rules as an “issuer,” must file an annual report on Form C-AR with the U.S. Securities and Exchange Commission (SEC), updating investors on the company’s financial condition until its reporting obligation terminates. A company must file its Form C-AR within 120 days after the end of its fiscal year. For companies with a December 31 fiscal year-end, the deadline is typically April 30, or April 29 in a leap year.
While intermediaries provide an array of services to their clients, this annual reporting obligation belongs solely to the company, not the intermediary. “Annual reporting is, and remains, the issuer’s own legal obligation,” said Brian Belley, President of the Crowdfunding Professional Association. “This best practice does not shift that responsibility to the intermediary. It gives funding portals and broker-dealers a practical, scalable way to make the obligation clear at the outset, which can help reduce inadvertent noncompliance and strengthen investor confidence.”
The best practice also comes on the heels of a new Corporation Finance Interpretation (CFI 202.02) published by SEC staff on July 9, 2026, addressing how the Rule 202(b)(2) holder-of-record threshold applies to offerings conducted through a crowdfunding vehicle (SPV) organized under Rule 3a-9 of the Investment Company Act of 1940.
The new CFI clarifies that a company using an SPV must count each of the investors who invested through the vehicle when determining whether it may terminate annual reporting. As a result, the company’s reporting obligation generally continues until there are fewer than 300 such investors, unless another termination condition under SEC rules applies. The SEC staff's Corporation Finance Interpretation 202.02 provides the full guidance.
CfPA emphasized that its standard issuer acknowledgement language is offered for consideration only and is not intended as legal, financial, or investment advice, and does not shift or create any compliance, monitoring, or filing obligation on the part of any intermediary. Intermediaries are encouraged to consult their own qualified legal and compliance professionals before adopting or distributing any such language to issuer clients.
“This is the kind of practical industry standard CfPA is developing,” Belley added. “By bringing stakeholders together around workable, voluntary solutions, we can improve market practices without waiting for every operational issue to be addressed through regulation.”
The full CfPA C-AR Annual Reporting Best Practice, including sample issuer acknowledgment language, is available online.
About the Crowdfunding Professional Association
The Crowdfunding Professional Association (CfPA) is a 501(c)(6) nonprofit trade association dedicated to fostering the growth of the regulated investment crowdfunding economy. CfPA supports issuers, investors, regulated intermediaries, and crowdfunding professionals through education, advocacy, industry engagement, and policy work. CfPA advocates for responsible growth of regulated investment crowdfunding, including Regulation Crowdfunding, Regulation A, intrastate crowdfunding, and related frameworks that expand access to private-market investment opportunities under established regulatory structures.
CfPA will convene journalists, policymakers, entrepreneurs, investors, and industry leaders at the 2026 Regulated Investment Crowdfunding Summit, October 20–21, 2026, in Washington, D.C. Registration is available at https://ricsummit.org.
Learn more at https://CfPA.org, https://www.crowdfundingecosystem.com, or join as a member at https://cfpa.org/joinus.
Media Contact Jason Fishman Vice President | Chair, Growth Committee Crowdfunding Professional Association, Inc. Email: press@cfpa.org Website: https://cfpa.org
Disclaimer: This release, and the best practice and sample language it describes, are for informational purposes only and do not constitute legal, financial, or investment advice. Nothing in this release, the underlying best practice, or the sample language it references, imposes, or should be construed to impose, any obligation on a funding portal or other intermediary to remind, monitor, ensure, or otherwise facilitate an issuer's compliance with its reporting obligations, nor any obligation to file on an issuer's behalf. Intermediaries and issuers should consult with their own qualified legal, financial, or compliance professionals before making any decisions related to fundraising, securities offerings, or compliance communications. The information provided is based on current regulatory requirements and publicly available sources as of the publication date and is subject to change.
