Broker dealers are registered with the SEC and governed by FINRA. The broker dealer is permitted to market and sell securities, and if they refer investors to the project, they can legally receive the finder''s fee from the project. In addition, it is advisable that agents overseas should direct their marketing efforts under the control and supervision of the broker dealer.
Who is required to register as a broker-dealer to conduct an EB-5 offering outside the United States?
From my understanding as an immigration attorney only, anyone soliciting the sale of securities should be registered.