b'disclose the nature, source, and amount of compensation they received in exchange for the promotion. The SEC found no issue with the fact that Kim was being paid for merely posting on social media. She got in trouble for not disclosing her compensationundertheSECsanti-toutingrule.Whydoestheanti-touting rule exist? Because the SEC believes that followers might view a paidadvertisementbyacelebrityasbiased,versusanuncompensated endorsement of an offering, which devoted followers might blindly follow.Kim Kardashian ultimately settled with the SEC and paid $1.26 million, which included $260,000 in disgorgement of her gain plus prejudgment interest,anda$1,000,000penalty,alongwithanagreementthatshe wouldnt promote any crypto asset securities for three years. Bottom line, if you have someone who will advertise your offering (assuming its a Rule 506(c), Regulation A+ or Regulation CF offering that canbeadvertised),andyouagreetocompensatethem;theamountof compensation, who pays it and when it will be paid must be disclosed in the advertisement. Consultant Finders In the course of my career, I have encountered professional finders that will ask for a flat fee (as much as $25k)weve had clients pay this where the person failed to make suitable introductions. Others want you to pay them $15k or more per month while they make introductions, some of which may not be suitable for your investments, either because you dont have the 247'