Compliance · How we work

We handle marketing and operations, not securities activity.

Apex Scalers is paid on a fixed-fee, subscription, or retainer basis. We do not solicit investors, negotiate deals, or earn transaction-based compensation. If a project moves into licensed territory, we stop and hand it off.

Scope of activity

What we handle, and where we stop.

In scope

  • 01Produce investor-facing marketing materials and financial models
  • 02Set up and organize data rooms to institutional standards
  • 03Run digital outreach campaigns and manage investor lists
  • 04Coordinate meetings and handle appointment logistics
  • 05Qualify inbound opportunities against objective criteria
  • 06Route qualified opportunities to the appropriate licensed entity
  • 07Refer out-of-scope opportunities to contracted partners

Out of scope

  • 01Recommend, endorse, or advise on any investment
  • 02Negotiate terms, price, or structure on behalf of any party
  • 03Solicit capital or pre-qualify investors for a transaction
  • 04Discuss deal specifics, diligence, or material non-public information
  • 05Receive transaction-based, contingent, or success-based compensation
  • 06Participate in the execution or closing of any transaction
  • 07Hold, custody, or transmit client or investor funds
Handoff protocol

When licensed work starts, we step back.

Any activity that requires broker-dealer, investment adviser, or equivalent registration triggers an immediate and documented handoff. Apex Scalers ceases the in-scope engagement; the counterparty is notified in writing; the licensed entity takes over under its own engagement terms.

Step 01

Trigger detected

The qualification engine flags an activity that crosses into solicitation, negotiation, or other licensed scope.

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Step 02 · Pause

Engagement freezes

In-scope work stops immediately. The counterparty is notified in writing that a handoff is in progress.

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Step 03

Licensed entity engages

The appropriate licensed entity contracts directly with the counterparty on its own terms and under its own supervision.

Operating principles
I

Compensation is fixed, known, and disclosed.

Every engagement is flat fee, subscription, or retainer. There is no variable compensation tied to whether a raise succeeds, what terms it prices at, or whether a transaction closes. The dollar amount is documented before any work begins.

II

We do not discuss deal specifics.

Our work is with marketing materials, operational coordination, and list management. We do not negotiate terms, recommend structures, or field questions that require a registered professional to answer. When those questions surface, the handoff protocol applies.

III

The routing ledger is the compliance record.

Every opportunity, evaluation, disposition, and handoff is recorded in the routing ledger with its input channel, criteria outcomes, and final destination. The ledger is versioned, immutable by operators, and available for audit.

IV

Licensed activity lives elsewhere.

Securities activity is routed to the appropriate licensed entity. Apex Scalers does not, and will not, conduct it directly. This is not a workaround; it is the design.

Questions for counsel

Counsel reviewing our posture can request a memorandum describing scope, compensation structure, and handoff procedures.

Request the memo