Two rules for every role
- UnyKorn LLC runs software. It does not hold investor money, sell securities or take a percentage of any offering. Every regulated job belongs to a partner that holds the license the law requires for that job.
- Nobody is paid per investor or per dollar raised through the platform. Broker-dealer reps are paid by their own broker-dealer. Real estate agents are paid real estate commissions by the seller, outside the platform. Referral partners earn a flat fee per signed platform customer, never per investor, per subscription or per dollar raised.
The thirteen roles
A market can need all thirteen. Each row names the rule that requires the role, or says it is a business need.
| Role | Required by | One firm, or per state |
|---|---|---|
| Securities counsel | Securities Act exemptions and Form D | One firm, with state filing coverage |
| SEC-registered transfer agent | Exchange Act section 17A(c)(1) | One firm |
| Broker-dealer, plus ATS or funding portal where used | Exchange Act section 15(a)(1); Regulation Crowdfunding; Regulation ATS | One firm if registered in every market state |
| Qualified custodian (where custody is required) | 17 CFR 275.206(4)-2(d)(6), the definition of a qualified custodian; business need | One firm |
| Escrow bank | 17 CFR 240.15c2-4; 17 CFR 227.303(e) | One bank |
| KYC/AML and accredited-investor verification | 31 CFR 1023.220 (through the broker-dealer); 17 CFR 230.506(c)(2)(ii); OFAC | One provider |
| Appraisers | Business need; 12 U.S.C. 3342 for federally related transactions | Per state |
| Title and closing agent | Business need: clear title, deed into the property company | Per state |
| Property managers | State real estate license law (for example Fla. Stat. 475.01) | Per market |
| Insurance broker | Business need; a producer license in each state | One broker if licensed in each state, else per state |
| Tax and K-1 preparer | IRS Form 1065 and Schedule K-1 for each property company | One firm |
| CPA / independent accountant | 17 CFR 230.251 and 230.257 (Regulation A Tier 2); 17 CFR 227.201 (Regulation Crowdfunding) | One firm licensed where the issuer needs it |
| Photographers and tour capture | Business need; FAA Part 107 for drone work | Per market |
What the main roles do
- Securities counsel picks the exemption for each offering, writes the offering documents and reviews public copy.
- Transfer agent keeps the official holder register. The token ledger must match it.
- Broker-dealer, ATS or funding portal sells the offering and handles any pay tied to a sale; its commission is paid by the issuer, outside the platform. After the lock ends, resale runs through a broker-dealer or an ATS.
- Qualified custodian holds an investor's securities or cash where a third party must hold them. It is opened in the client's own name. Securities counsel decides whether an offering needs one.
- Escrow bank holds investor payments until the offering closes, then releases or returns them.
- KYC/AML provider verifies identity, screens against government lists and, in a Rule 506(c) offering, confirms that each buyer is accredited.
- Title and closing agent closes the purchase and records the deed in the property company's name.
Where the roles stand today
The platform's integrations list shows these roles as not connected today: KYC and AML provider, accredited investor verification, ACH and wire bank rail (escrow account per offering), qualified custody, SEC-registered transfer agent, and broker-dealer or ATS for resale. No custodian is engaged. The transfer agent partner is not yet chosen.
One check is connected. The platform's integrations list shows OFAC screening as connected. Names and wallet addresses are checked against the Treasury OFAC SDN list. A similar name opens a human review.
A market stays on sample data until every role it needs is filled under a signed agreement.
Check the register, not the pitch
Each of these registers is public:
- Broker-dealers: FINRA BrokerCheck shows the firm profile, owners and the states where it is registered.
- Transfer agents: SEC EDGAR holds Form TA-1 and Form TA-2 filings.
- Appraisers: the ASC National Registry.
- Title agents: the ALTA Registry.
- Insurance producers: NIPR.
- CPAs: CPAverify.
- Drone pilots: the FAA Airmen Inquiry.
- Sanctions: the OFAC Sanctions List Search.
Not legal advice. Securities and real estate counsel in United States sign off before any first close.