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How to Verify Required Documentation Is Complete

Overview​

As a broker on the WhiteLabel Community Deals Platform, ensuring that issuers have provided all necessary documentation is a critical part of the deal review process. Complete and accurate documentation protects investors, ensures regulatory compliance, and reduces liability for all parties involved. This guide will walk you through the process of verifying that all required documents are present, complete, and meet platform standards.

Prerequisites​

Before reviewing deal documentation, you should:

  • Have an active broker account on the platform
  • Have accessed a pending deal for review
  • Understand the documentation requirements for different deal types
  • Be familiar with standard disclosure documents for securities offerings
  • Know which documents are mandatory versus optional for specific offering types

Step-by-Step Instructions​

Step 1: Access the Deal Documents Tab​

  1. From the Broker Dashboard, access the pending deal you want to review
  2. On the Deal Approval page, click on the "Documents" tab
  3. This will display all documents uploaded by the issuer
  4. Note the number of documents indicated (e.g., "Documents: 2")

Step 2: Understand Documentation Requirements​

Different offering types require different documentation. Here's what to expect for common offering types:

Regulation D (506b/506c) Offerings:

  • Private Placement Memorandum (PPM)
  • Subscription Agreement
  • Operating Agreement or Bylaws
  • Investor Questionnaire
  • Financial Statements
  • Business Plan or Executive Summary

Regulation A+ Offerings:

  • Offering Circular (Form 1-A)
  • SEC Qualification Notice
  • Subscription Agreement
  • Financial Statements (audited for Tier 2)
  • Corporate Governance Documents

Regulation CF Offerings:

  • Form C
  • Financial Statements
  • Business Plan
  • Corporate Documents
  • Subscription Agreement

Step 3: Review Document Completeness​

  1. Check that all required documents for the specific offering type are present

  2. For each document category, verify:

    • The document is properly named and categorized
    • The file is in an acceptable format (usually PDF)
    • The document is complete (not missing pages or sections)
    • The document is properly signed if signatures are required
    • The document is current and not outdated

  3. Use a mental or written checklist to track which required documents are present

Step 4: Verify Private Placement Memorandum (PPM) or Offering Circular​

  1. For the PPM or Offering Circular, verify it contains:

    • Company overview and business description
    • Details of the securities being offered
    • Complete risk factors section
    • Management team information
    • Capitalization structure
    • Use of proceeds
    • Subscription procedures
    • Transfer restrictions
    • Tax considerations
    • All required regulatory disclosures

  2. Check that the document is professionally prepared and free of obvious errors

  3. Verify consistency with other deal information on the platform

Step 5: Review Subscription Agreement​

  1. Verify the Subscription Agreement includes:

    • Clear terms of the investment
    • Investor representations and warranties
    • Accreditation standards (if applicable)
    • Payment instructions
    • Signature blocks for all parties
    • Cancellation rights (if applicable)
    • Minimum/maximum investment amounts
    • Closing conditions

  2. Check that the agreement is specific to the current offering

  3. Verify it aligns with the terms described in the PPM and on the platform

Step 6: Examine Financial Statements​

  1. Verify the appropriate level of financial statements are provided:

    • For Reg D: Financial statements appropriate to deal size
    • For Reg A+ Tier 2: Audited financial statements
    • For Reg A+ Tier 1: Reviewed financial statements
    • For Reg CF: Financial statements (level depends on raise amount)

  2. Check that financial statements include:

    • Balance sheet
    • Income statement
    • Cash flow statement
    • Notes to financial statements
    • Appropriate level of review or audit

  3. Verify statements are current (typically within 120 days for ongoing offerings)

Step 7: Review Corporate Documents​

  1. Verify corporate formation and governance documents:

    • Articles of Incorporation or Organization
    • Bylaws or Operating Agreement
    • Board resolutions authorizing the offering
    • Shareholder agreements (if applicable)
    • Evidence of good standing

  2. Check that these documents establish the issuer's legal authority to conduct the offering

  3. Verify consistency with the company structure described in other documents

Step 8: Check Additional Supporting Documents​

  1. Review any additional documents provided:

    • Business plan
    • Executive summary
    • Marketing materials
    • Technical white papers (for technology offerings)
    • Intellectual property documentation
    • Material contracts
    • Industry analysis

  2. Verify these documents provide substantive information to investors

  3. Check for consistency with primary offering documents

Step 9: Identify Missing or Incomplete Documents​

  1. Based on your review, identify any required documents that are:

    • Missing entirely
    • Incomplete or partial
    • Outdated
    • Improperly executed
    • Inconsistent with other documents
    • Of poor quality or unprofessional

  2. Create a clear list of document deficiencies that need to be addressed

Step 10: Document Your Findings​

  1. Click on the "Comments" tab

  2. Add detailed comments about document completeness:

    • List any missing required documents
    • Note incomplete sections within documents
    • Highlight inconsistencies between documents
    • Suggest improvements for clarity or completeness

  3. Be specific in your feedback, referencing document names and sections

  4. Distinguish between critical document issues and minor suggestions

Step 11: Determine Next Steps​

  1. Based on your document review, determine the appropriate action:

    • Approve: If all required documents are complete and satisfactory
    • Comment: If minor document improvements are needed but not deal-breakers
    • Request Changes: If significant document issues need to be addressed
    • Reject: If critical documents are missing or fundamentally flawed

  2. If requesting changes, clearly communicate what documents need to be added or revised

Best Practices​

  • Use a Checklist: Maintain a standard checklist of required documents by offering type
  • Be Thorough: Review documents completely, not just checking that they exist
  • Focus on Materiality: Prioritize issues that could impact investor decision-making
  • Check Consistency: Verify that information is consistent across all documents
  • Consider the Audience: Ensure documents are understandable to their intended readers
  • Document Everything: Keep detailed notes on your document review
  • Provide Specific Feedback: Give clear, actionable feedback on document issues
  • Maintain Standards: Apply consistent documentation standards across all deals
  • Respect Confidentiality: Handle all issuer documents with appropriate confidentiality
  • Verify Authenticity: Be alert for signs that documents may not be authentic

Troubleshooting​

Common Issues​

  1. Documents Uploaded in Wrong Format

    • Solution: Request the issuer to upload in the correct format (usually PDF)
    • Solution: Explain which formats are acceptable on the platform

  2. Incomplete or Draft Documents

    • Solution: Request final, complete versions
    • Solution: Specify exactly which sections are missing or incomplete

  3. Outdated Financial Information

    • Solution: Request current financial statements
    • Solution: Specify the date range that would be acceptable

  4. Missing Signature Pages

    • Solution: Request fully executed documents
    • Solution: Clarify which parties need to sign each document

  5. Inconsistencies Between Documents

    • Solution: Highlight specific inconsistencies
    • Solution: Request reconciliation of contradictory information

Getting Help​

If you encounter issues during the document review process:

  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 document-related question
  4. Submit your support request
  5. Support staff will respond through the platform's notification system