Aggregator Business Model Finder Sales 
Scott Edward Walker
JANUARY 13, 2012
Precisely because of this profile, however, such offerings are uniquely subject to fraud, and some issuers will simply be phantom companies without any assets, business model, or real world existence.”
Startup Company Lawyer
MAY 26, 2012
On April 23, 2012, the SEC published guidance reminding issuers that “any offers or sale of securities purporting to rely on the crowdfunding exemption would be unlawful under federal securities laws” until the SEC adopts new rules. Some companies utilize pure donation models. Crowdfunding Prior to the JOBS Act.
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