Can You Run a Reg-CF Offering on Two Platforms at Once? The Single-Intermediary Rule

No. A Regulation Crowdfunding offering may be conducted through exactly one intermediary, and an issuer cannot run concurrent Reg-CF offerings across two portals. Rule 100(a)(3) conditions the Section 4(a)(6) exemption on the transaction being "conducted exclusively through the intermediary's platform," and the Instruction to that paragraph states plainly that an issuer shall not conduct an offering or concurrent offerings in reliance on Section 4(a)(6) using more than one intermediary.

Regulation D and Regulation A+ contain no equivalent condition. That asymmetry is the whole answer, and it drives a set of practical decisions — which portal to pick, what happens if the choice turns out badly, and where a second distribution channel is actually available.

What the Single-Intermediary Rule Covers

Rule 100(a) sets four conditions on the crowdfunding exemption: the twelve-month aggregate sold in reliance on Section 4(a)(6) may not exceed $5,000,000; per-investor limits apply to non-accredited purchasers; the transaction must run through a compliant intermediary and exclusively on that intermediary's platform; and the issuer must meet the Section 4A(b) disclosure obligations.

The third condition is the one at issue, and it is worth reading precisely. It restricts the transaction — investment commitments, the subscription flow, escrow, cancellation and reconfirmation mechanics. It does not restrict where an issuer advertises. Off-platform marketing is permitted, but it is separately capped by Rule 204, which limits a public notice to a closed list of items and requires that the notice direct investors to the intermediary's platform. In other words: one place to invest, many places to be told about it.

The intermediary itself is not an arbitrary choice of vendor either. Under Rule 300(a), a person acting as an intermediary must be registered with the Commission as a broker under Exchange Act Section 15(b) or as a funding portal under Rule 400, and be a member of a national securities association registered under Section 15A. An issuer relying on an entity that is neither has not satisfied Rule 100(a)(3). The distinction between the two categories of intermediary is covered in our breakdown of funding portals versus broker-dealers.

How the Three Exemptions Compare on Distribution

A caution on the two right-hand rows: the absence of a platform-exclusivity rule is not the absence of regulation. Anyone soliciting or effecting securities transactions for transaction-based compensation may fall within the broker definition under Exchange Act Section 15(a), and issuers typically work through registered intermediaries in Reg-D and Reg-A+ raises for that reason. Consult counsel on how any distribution arrangement is structured and compensated.

Switching Portals Mid-Raise Is a Relaunch, Not a Migration

Because only one intermediary can carry the offering, moving is not a matter of exporting a list. The old offering is terminated and a new one is commenced on the new platform, and the paperwork follows that reality.

1. The existing offering closes or is withdrawn. There is no mechanism by which live investment commitments on Portal A become live commitments on Portal B. Funds held by the qualified third party under the first offering are handled under that offering's terms.
2. Investors do not carry over. Each investor makes a fresh commitment on the new platform, subject to that intermediary's account opening, investor education and limit checks. Practically, this is a re-conversion event, and the drop-off between the two lists is the real cost of switching.
3. Form C obligations re-attach. Under Rule 203(a)(1), a Form C offering statement is filed with the Commission and provided to investors and the relevant intermediary before the offering commences. A different intermediary is a different offering record.
4. Material changes inside a live offering trigger reconfirmation. Rule 203(a)(2) requires an amendment on Form C/A for material changes, additions or updates, and where the amendment reflects material changes the issuer checks the box indicating that investors must reconfirm within five business days or the commitment is considered cancelled. Rule 304(c) puts the corresponding notice obligation on the intermediary.
5. Timing resets. Rule 304(b) permits an early close only where the offering has remained open a minimum of 21 days under Rule 303(a), investors have been noticed, and the new deadline falls at least five business days after that notice. A relaunched offering starts that clock again.

The compounding problem is that a switch usually happens mid-campaign, when paid traffic is already running against a live URL. Every ad, email and press placement points at a listing that is about to stop existing. Issuers who treat the portal as interchangeable infrastructure discover it is the endpoint of the entire funnel.

Where a Second Channel Is Actually Available: Concurrent Offerings

The Instruction to Rule 100(a)(3) blocks concurrent Reg-CF offerings across intermediaries. It does not block a Reg-CF offering running alongside an offering made under a different exemption. That is the legitimate route to a second investor pool — a Reg-CF listing for retail participation and a Rule 506(c) round for accredited capital, structured so each stands on its own exemption.

The constraint there is integration. Rule 152 sets a general principle plus non-exclusive safe harbors, and it states that its provisions will not avoid integration for a series of transactions that is part of a plan or scheme to evade registration. For two concurrent exempt offerings that both permit general solicitation, the rule requires satisfying the particular exemption relied on and addresses how general solicitation materials interact. We covered the mechanics in detail in concurrent offerings and Rule 152 integration.

The marketing implication is specific: two exemptions means two audiences with two different qualification paths, not one audience shown two buttons. Retail traffic and accredited traffic should be separated at the ad and landing-page level, because the disclosure, verification and messaging obligations diverge from the first click.

Choosing the One Intermediary

Since the decision is effectively irreversible inside a live raise, it deserves diligence before the Form C is filed rather than after. A workable order of evaluation:

1. Registration and association membership. Confirm the entity is a registered broker or a registered funding portal and a member of a national securities association, as Rule 300(a) requires. This is a check against public records, not a claim to accept from a sales deck.
2. Security types supported. Not every portal handles every instrument. If the raise is a SAFE, a convertible note, a revenue-share or a token-linked instrument, confirm support before committing.
3. Escrow and the qualified third party. Ask who holds funds, how the minimum is tested and what the release mechanics look like against your target deadline.
4. Conversion quality of the checkout. The number that matters is the share of arriving visitors who finish a commitment. Account creation friction, identity checks and investor-limit prompts all sit between the ad click and the closed subscription.
5. Fee structure across the full raise. Platforms differ in how they combine a percentage of the amount raised, listing or setup charges, escrow and processing costs, and securities-based compensation. Compare on total loaded cost at your realistic raise size, not on the headline rate.
6. Data access and reporting. Off-platform paid media is only as good as the attribution feeding it. Establish before launch what commitment-level and traffic-level data the intermediary makes available, and at what cadence.

A comparison of the venues issuers most often shortlist is maintained on our platforms overview.

Frequently Asked Questions

Can an issuer list the same Reg-CF offering on Wefunder and StartEngine at the same time?

No. The Instruction to Rule 100(a)(3) states that an issuer shall not conduct an offering or concurrent offerings in reliance on Section 4(a)(6) using more than one intermediary, and Rule 100(a)(3) requires the transaction to be conducted exclusively through the intermediary's platform. One Reg-CF offering runs on one portal. Issuers may still promote that single listing across any number of external channels, subject to the Rule 204 notice limits.

Can you switch crowdfunding platforms in the middle of a raise?

An issuer can stop one offering and commence another on a different intermediary, but the commitments do not transfer and every investor must re-subscribe on the new platform. Form C obligations attach to the new offering, and Rule 203(a)(2) requires a Form C/A with a reconfirmation checkbox where a live offering undergoes material changes. Treat the move as a relaunch with its own conversion cost, and consult counsel on sequencing.

Does the single-intermediary rule apply to Reg-A+ offerings?

No. Regulation A contains no condition requiring the offering to run exclusively through one platform, which is why Reg-A+ issuers commonly combine an issuer-hosted offering page with a broker of record and syndicated distribution. The governing gate for Reg-A+ is SEC qualification of the Form 1-A, not the venue. Broker registration questions still apply to anyone selling on the issuer's behalf.

Can a company run a Reg-CF offering and a Reg-D 506(c) round at the same time?

Concurrent offerings under different exemptions are contemplated by Rule 152, which provides a general integration principle and non-exclusive safe harbors. Each offering must independently satisfy its own exemption, and Rule 152 expressly declines to avoid integration where the structure is part of a plan or scheme to evade registration. This is a facts-and-circumstances analysis that counsel should run before either offering commences.

Where can a Reg-CF issuer advertise if only one platform can carry the offering?

Anywhere, within limits. Rule 204(b) permits a notice that directs investors to the intermediary's platform and contains no more than the statutory list: a statement that the offering is made under Section 4(a)(6), the intermediary's name and a link, the terms of the offering, and defined factual information about the issuer. Rule 204(c) separately allows fuller discussion through the communication channels the intermediary provides, provided the issuer identifies itself.

Building the Demand That Feeds a Single Listing

The single-intermediary rule concentrates risk in one place. Every dollar of paid media, every email and every earned placement resolves to one checkout on one platform, and there is no second venue absorbing the traffic the first one loses. That makes two things decisive: choosing the intermediary on conversion economics rather than brand familiarity, and owning the demand generation upstream of it so the audience belongs to the issuer rather than to the portal.

Growth Turbine has provided marketing support across more than $490M in aggregate issuer-reported totals, with 200+ campaigns supported across Reg-CF, Reg-D 506(c), Reg-A+ and tokenized securities offerings, on 23+ crowdfunding platforms and across 25+ industries. That platform range is what makes the pre-filing choice tractable — the differences between portals show up in conversion data long before they show up in a pitch deck. To plan a raise around one listing, start with our Reg-CF equity crowdfunding services, or review the broader equity crowdfunding marketing approach if the raise may span more than one exemption. To discuss a specific offering, get in touch.

Disclaimer: The information provided in this article is for educational and informational purposes only and does not constitute legal, financial, or investment advice. Always consult with qualified legal counsel and financial advisors before launching a capital raise.