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How to Add Constructive Comments for Issuers

Overview

As a broker on the WhiteLabel Community Deals Platform, providing clear, constructive feedback to issuers is essential for improving deal quality and ensuring regulatory compliance. Effective communication helps issuers understand what changes are needed before their deals can be approved, streamlining the review process and building positive working relationships. This guide will walk you through best practices for providing helpful, actionable feedback to issuers.

Prerequisites

Before providing feedback to issuers, you should:

  • Have an active broker account on the platform
  • Have reviewed the deal details, documentation, and compliance aspects
  • Have identified specific areas requiring improvement or clarification
  • Understand the platform's commenting system and communication tools
  • Be prepared to explain the reasoning behind your feedback

Step-by-Step Instructions

Step 1: Access the Deal Comments Section

  1. From the Broker Dashboard, access the pending deal you've reviewed
  2. On the Deal Approval page, click on the "Comments" tab
  3. This will display the comment interface where you can add feedback
  4. Note any existing comments or conversation history with the issuer

Step 2: Organize Your Feedback

  1. Before writing comments, mentally organize your feedback into categories:

    • Critical issues that must be resolved before approval
    • Important suggestions that would significantly improve the deal
    • Minor recommendations that are helpful but not essential
    • Questions requiring clarification from the issuer
  2. Consider grouping related feedback points together for clarity

  3. Prioritize the most important issues that need addressing

Step 3: Write Clear, Specific Comments

  1. Click on the "Comment" button to open the comment editor

  2. Write your feedback following these guidelines:

    • Be specific about what needs to be changed or improved
    • Reference exact documents, sections, or pages when applicable
    • Explain why the change is necessary (regulatory requirement, investor protection, etc.)
    • Provide clear guidance on what would resolve the issue
    • Use professional, constructive language
  3. Example of a well-structured comment:

    In the Private Placement Memorandum, the Risk Factors section (pages 15-17) needs expansion. 
    Specifically, please add risks related to:
    1. Industry competition
    2. Regulatory changes
    3. Technology obsolescence

    These additions are necessary to meet disclosure requirements and provide investors with a complete understanding of potential risks.

Step 4: Use the Comment Editor Tools

  1. Utilize the comment editor formatting tools to enhance clarity:

    • Use bullet points or numbered lists for multiple items
    • Bold text to emphasize critical points
    • Use paragraph breaks to separate distinct issues
    • Include links to relevant resources if applicable
  2. Preview your comment before submitting to check formatting and clarity

Step 5: Add Document-Specific Comments

  1. For document-specific feedback, you can:

    • Reference the document name and page number in your comment
    • Use the document viewer's annotation tools if available
    • Upload marked-up versions of documents if the platform supports this
  2. Be precise about where in the document changes are needed

  3. Provide examples of acceptable language or content when helpful

Step 6: Include Educational Context

  1. When appropriate, include educational context with your feedback:

    • Explain the regulatory basis for your requirement
    • Reference industry best practices
    • Provide the reasoning behind your suggestion
    • Link to platform guidelines or resources
  2. This helps issuers understand why changes are needed, not just what changes

Step 7: Maintain a Professional, Constructive Tone

  1. Ensure your feedback is:

    • Professional and respectful
    • Focused on the deal, not personal criticism
    • Solution-oriented rather than just pointing out problems
    • Clear about expectations
    • Encouraging of improvement
  2. Avoid language that could be perceived as:

    • Condescending or dismissive
    • Vague or ambiguous
    • Unnecessarily harsh or negative
    • Overly technical without explanation

Step 8: Set Clear Expectations for Next Steps

  1. Conclude your feedback with clear next steps:

    • Indicate whether you're requesting changes before approval
    • Specify if you need a response to questions
    • Set expectations for timeline if applicable
    • Explain what will happen after the issuer addresses your feedback
  2. Example:

    Please address these items and resubmit the updated documents through the platform. 
    Once the changes are made, I'll review the updates and proceed with the approval process
    if all items have been adequately addressed.

Step 9: Submit Your Comments

  1. Review your complete feedback for clarity, tone, and completeness
  2. Click the "Submit" or "Send" button to post your comments
  3. The issuer will be notified of your comments according to their notification settings

Step 10: Follow Up on Issuer Responses

  1. Monitor the platform for issuer responses to your feedback

  2. When the issuer responds:

    • Review their answers to your questions
    • Check if they've uploaded revised documents
    • Verify that all requested changes have been made
    • Provide additional clarification if needed
  3. Acknowledge progress and improvements in your follow-up communications

Best Practices

  • Be Specific: Provide exact details about what needs to be changed and where
  • Explain Why: Help issuers understand the reasoning behind your feedback
  • Prioritize Issues: Clearly indicate which issues are most critical to address
  • Offer Solutions: When possible, suggest specific ways to resolve issues
  • Be Timely: Provide feedback promptly after reviewing a deal
  • Be Comprehensive: Address all issues in one round of feedback when possible
  • Maintain Consistency: Apply the same standards across all deals
  • Be Accessible: Make yourself available for clarification questions
  • Document Everything: Keep a record of all feedback provided
  • Balance Criticism with Positivity: Acknowledge strengths along with areas for improvement

Troubleshooting

Common Issues

  1. Issuer Misunderstands Feedback

    • Solution: Clarify your comments with more specific examples
    • Solution: Offer a call or video conference for complex issues
    • Solution: Break down complex requirements into smaller, clearer steps
  2. Issuer Disagrees with Feedback

    • Solution: Provide regulatory citations or platform policies that support your requirements
    • Solution: Explain the investor protection rationale
    • Solution: Consider if there are alternative ways to address the underlying concern
  3. Issuer Makes Partial Changes

    • Solution: Create a checklist of required changes and mark which have been completed
    • Solution: Be explicit about which items still need addressing
    • Solution: Acknowledge progress while being clear about remaining issues
  4. Communication Breakdown

    • Solution: Suggest a different communication channel if text comments aren't effective
    • Solution: Involve a platform administrator if necessary
    • Solution: Reset the conversation with a clear, concise summary of outstanding issues
  5. Repeated Issues Across Multiple Deals

    • Solution: Create standardized feedback templates for common issues
    • Solution: Suggest educational resources for the issuer
    • Solution: Consider if platform guidance needs improvement

Getting Help

If you encounter challenges in providing effective feedback:

  1. Navigate to the /support Support center by clicking on the "Support" link in the main navigation
  2. Select the appropriate category for your issue
  3. Provide specific details about your communication challenge
  4. Submit your support request
  5. Support staff will respond through the platform's notification system