On September 21, 2021, National Instrument 45-110 Start-up Crowdfunding Registration and Prospectus Exemptions (NI 45-110) came into force and provides a harmonized national framework to facilitate securities crowdfunding for start-ups and early stage issuers.
Patro, your client has zero business 'doing' crowdfunding as it is CLEARLY not permitted.
"NI 45-110 provides an exemption from the prospectus requirements that allows an issuer to distribute eligible securities through an online funding portal and an exemption from the dealer registration requirement for funding portals that facilitate online distributions by issuers relying on this prospectus exemption."
Issuer Requirements
Issuers must satisfy several conditions to make distributions under the start-up crowdfunding prospectus exemptions in NI 45-110:
The issuer cannot be a reporting issuer or an investment fund.