Thanks for your feedback, Bill.  However, if all I am doing is acting as a passive finder making the introductions, this exempts me from any FINRA/SEC requirements, right?  Also, I have met with a securities attorney with 25 yrs experience, discussed my role in these transactions and status.  She did not raise any concerns. 

I did not ask her specifically if I was in compliance and I should have.  However, a prudent person would assume that since she did not raise any concerns, that everything I am doing is above-board, yes?

So you hired a 25 year veteran securities attorney, and you trusted her opinion so much that you wanted to come on an anonymous chatroom to ask people's opinions?  But you didn't SPECIFICALLY ask her if you were in compliance, so you just ASSUME, by her not raising any concerns (to a question you didn't ask) that you are, in fact, in compliance.

Looks like you've dotted all your I's and crossed your T's.  Good business plan.

Honestly X-Man, I think you should circle back with your attorney.  Bill is very knowledgable, but let's face it, you didn't hire him, he doesn't know your full story, and this IS just an online chatroom.  Maybe you should just hire Bill.  In 5 minutes, he could probably tell you what you need to know.

:D  no need for the snarky comments, BK24...

I did follow up with a casual email to the attorney and her reply was to discuss in person.  I've dealt with attorneys before and being a frugal business-man, do not want to incure a $800 bill for a simple question.  If I WAS in any violation, I would hope that she would let me know.

Additionally, since I know of many other reputable professionals that deal in private equity as passive finders, I believe it's safe to assume that I'm okay.  Would just like validation of some sort without the $800 bill.   Fair enough?  :)

anyone???

You lawyers are all the same.  No wonder everyone hates lawyers. Buy-bye