b'one in management can be paid a fee based on the amount of capital they raise.2.The common law finders exception allows mere introductions - but nothing more, and it is questionable whether it would apply to referrals of non-accredited investors. All such compensation must be disclosed to investors (when, how much, and who pays it) at the time the solicitation is made.3.The burden is on the finder or capital raiser to prove to the SEC that it didnt act an unlicensed broker, and the more frequently a finder engages in these activities (such as raising capital or serving as a finder for multiple issuers), the less likely they are to prevail. Further, even if a finder prevails in its arguments to the SEC, it may fail when scrutinized by state securities regulators.Stillwanttopaycapitalraisersorfinders?Runyourproposed compensationmodelpastyourcorporatesecuritiescounselbeforeyou commit. You may want to pay them to obtain a no action letter, draft an opinion letter or written memorandum, just to make sure your proposed compensation model is not going to get you, the capital raiser, or finder in trouble.What Other Jobs Can You Do? Below is a list of 12 jobs required to manage a successful syndicate. Some of these are jobs that capital raisers can do in addition to raising capital, and thus, justify their compensation, but word to the wise, dont 251'