Each candidate way of paying a creator is scored 1–5 on nine axes, then rolled into one weighted total so mechanisms can be ranked and their trade-offs made explicit. The organizing tension the framework surfaces: the mechanisms that convert best — fill the SPV, grow the RIA book — tend to carry the worst legal and compliance risk. The three legal/brand axes are graded adversarially against the primary law archived under Sources, and each carries a DRIL evidence tag recording how well-grounded the score is. This page is a decision aid, not legal advice; every legal characterization is counsel-gated.
The nine scoring axes
Each axis is scored 1–5. On the good axes (SPV alignment, RIA alignment, combined-entity fit) and the two conversion axes, higher is better. On the four risk axes (complexity, brand, hard legal, compliance), higher is worse. Each definition below carries an id anchor; tooltip terms elsewhere on the site point to it.
1 · SPV alignment higher = better
Does it advance the deal engine / sourcing? 1 = decoupled from deals by design; 5 = paid on realized deal outcomes / at-risk in the deal.
2 · RIA alignment higher = better
Does it advance wealth AUM / advisory conversion? 1 = aimed at capital not advisory relationships; 5 = paid on advisory clients delivered.
3 · Combined-entity fit higher = better
Does it advance the HoldCo flywheel as one? 1 = needs a BD/CAB build or a second adviser (or fits nothing); 5 = runs cleanly inside one adviser + MediaCo.
4 · Complexity risk higher = WORSE
Operational/structural machinery to run. 1 = one-time grant/disclosure only; 5 = build-and-supervise a BD/CAB or a multi-doc external GP stack + per-deal consent.
5 · Brand risk to the creator higher = WORSE
Personal-brand/securities exposure. 1 = minimal personal exposure; 5 = creator becomes an unregistered broker with bad-actor taint + personal rescission/aiding-abetting liability.
6 · Hard legal risk higher = WORSE
Does it require registration / is it a Ranieri/Van Eck/15(a) transaction-based-comp pattern? 1 = no transaction nexus; 5 = the Exchange Act 15(a)/Ranieri violation itself (voided exemptions, rescission, 20(e) liability).
7 · Ongoing compliance burden higher = WORSE
Recurring upkeep. 1 = grant-then-passive; 5 = continuous point-of-endorsement disclosure + 506(d) re-screening + adviser/FINRA supervision.
8 · Expected RIA conversion higher = better
How much it drives creators to deliver advisory clients. 1 = pulls toward capital/deals; 5 = directly incentivizes delivering advisory clients.
9 · Expected SPV conversion higher = better
How much it drives deal participation. 1 = decoupled from deals by design; 5 = built to move deal capital / fill allocations.
Weighting scheme & the weighted-total formula
Weights encode the platform's strategy — they are the team's to tune, and re-tuning them re-sorts the ranking (adjust them live in the interactive model). Three principles drive the defaults: legal risk is existential (heaviest single penalty); the RIA is the crown jewel (RIA alignment + conversion weighted above their SPV counterparts); creators are the scarce asset (brand risk gets real weight).
| Axis | Sign | Default weight |
|---|---|---|
| SPV alignment | + | 1.0 |
| RIA alignment | + | 1.5 |
| Combined-entity fit | + | 1.0 |
| Complexity risk | − | 1.0 |
| Brand risk | − | 1.5 |
| Hard legal risk | − | 3.0 — heaviest; legal risk is existential |
| Compliance burden | − | 1.5 |
| RIA conversion | + | 2.0 |
| SPV conversion | + | 1.0 |
Weighted-total formula
Risk axes enter as negative penalties. Higher total = better all-in fit under these weights. Because hard legal risk is weighted 3.0 and negative, the anti-pattern is driven to the bottom by construction — the intended behavior.
Total = (1.0 · SPValign)
+ (1.5 · RIAalign)
+ (1.0 · CombinedFit)
+ (2.0 · RIAconv)
+ (1.0 · SPVconv)
− (1.0 · Complexity)
− (1.5 · BrandRisk)
− (3.0 · HardLegalRisk)
− (1.5 · ComplianceBurden)The binding firewall the legal grading turns on: Paid for clients / content / ownership / genuine-GP-work = curable. Paid for capital raised = curable ONLY by registration. Capital-keyed pay to an unregistered person is the anti-pattern; capital-keyed pay is acceptable only on the two registered-rep mechanisms. Confirmed by Ranieri Partners (transaction-based comp to an unregistered solicitor = §15(a) violation) and Van Eck (a registered adviser's AUM-linked finfluencer comp becomes existential once it scales and is hidden).
DRIL evidence-status legend
Each legal score carries an evidence status classifying how well-grounded it is — checked, per mechanism, against the actual archived primary source (method: DRIL, Afonso et al., NBER WP 35188). A score's number (1–5) is its risk level; its status is the strength of the law behind it.
A cited archived primary source contains verbatim, on-point support — a rule subsection or case holding that directly governs this fact pattern.
A reasoned extension of the primary law to a fact pattern the source does not directly adjudicate (an analogy/distinction). Sound, but the firm's position, not a holding.
Leans on a source that is not primary or not archived (a no-action letter, a memo, a secondary summary) standing in for primary law. Audit these.
The axis has no legal-source dependency — e.g. grant-then-passive equity triggers no live regime, so no rule is invoked and none is missing.
Across all 14 mechanisms, the overall distribution is 0 answered · 10 inferred · 4 proxy-used. No mechanism is answered on all three legal axes. This is not a defect in the scoring — it is the true state of the question: there is no SEC enforcement action directly on point for a creator-fed RIA/SPV platform, so the entire compliance thesis is reasoning-by-distinction from Ranieri (transaction-based comp) and Van Eck (AUM-linked finfluencer comp), which govern adjacent fact patterns. The bright-line calls (the anti-pattern's hard-legal 5; the registered-rep §15(a) cure; most Marketing-Rule burden scores) are answered on verbatim law. The clean recommendations (HoldCo equity, flat media, MediaCo rev-share) are inferred — clean by absence of the trigger, which is exactly where counsel confirmation is load-bearing.
The proxy-used audit list (weakest-grounded — fix before external use)
- Qualified-lead fees — hard legal: leans on Reg CF Rule 305 (bar on paying for offering-specific investor PII), which is not in the primary archive (self-flagged as memo-drawn). Archive Rule 305 or drop the pillar.
- Bona-fide co-GP carry — compliance burden: leans on the AngelList / FundersClub no-action letters — SEC staff guidance, not primary law and not archived. Non-precedential; archive the letters and flag their limits, or downgrade.
- Affiliated BD / CAB — compliance burden: same no-action / staff-guidance dependency for the CAB-activity-limits characterization.
- Registered IAR employment — compliance burden: load-bearing citation is 17 CFR 275.204A-1 (code of ethics / access-person reporting), plus Series 65/66 and Form U4 mechanics — none of which are in the archived folder.
Newly-identified items coverage-gap review
The last five items on this site — 3 mechanisms and 2 structures — were newly identified in a coverage-gap review. The original framework under-modeled two surfaces: the media-P&L surface (how a standalone MediaCo actually monetizes and pays creators) and the regulated-retail path (how the platform reaches its non-accredited audience lawfully). Each newly-identified item was scored to the same nine-axis standard and co-verified against the same primary law; each is flagged with the newly identified badge throughout the site.
| Item | Layer | Gap it closes |
|---|---|---|
| MediaCo revenue share new | Mechanism | Media-P&L surface — a share of MediaCo's own commercial revenue, distinct from a flat retainer. |
| Creator-holdco equity purchase new | Mechanism | Media-P&L / retention surface — the platform buys into the creator's business (inverted equity). |
| Registered IAR employment new | Mechanism | The most RIA-native path — the creator becomes a licensed adviser rep. |
| Regulated-retail wrapper new | Structure | Regulated-retail path — interval fund / Reg A+ / BDC that reaches non-accredited retail. |
| SMA-only / no-SPV new | Structure | Lowest-surface path — managed accounts only, deletes the entire pooled-vehicle problem. |
On the default weights, the newly-identified media/holdco mechanisms are among the lowest-legal-risk options and rise toward the top when compliance-safety is weighted above RIA-growth — adjust the weights in the interactive model to see the ranking re-sort.