Do we need a broker dealer license for our advertising agency? (Performance-based)

[Vitaliy Gnezdilov]

Hello all,

We’re a marketing company who creates advertising campaigns on behalf of 506c syndications (RE funds).

Specifically, we act on behalf of the client to set up and manage their ad campaigns that bring them accredited investor leads.

To be most aligned with our clients, we work with their marketing teams to create the assets and help investor relations guide prospective investors across the finish line (on a sales consulting side)—we do not interface with investors, and ultimately the client owns every marketing asset/investor relationship that resulted from our collaboration.

From a compensation standpoint, we want to align ourselves as much as possible with the results that we deliver for our clients. The ultimate metric we want to measure is capital raised.

What is the best way for our little marketing/advertising company to only get paid when our clients get capital across the finish line from our advertising efforts (which were created on our their ad accounts, using their branding, etc)?

Is there a way to do this without becoming a full fledged broker dealer?