pty-ltd-share-issue-compliance

Executive Summary

A proprietary limited company (Pty Ltd) with approximately 200 non-employee shareholders is in serious and ongoing breach of section 113(1) of the Corporations Act 2001 (Cth), which caps non-employee shareholders at 50. This breach exposes the company to ASIC-directed forced conversion to a public company under s 165, criminal penalties including up to 1 year imprisonment, and the unintended application of Chapter 6 takeover rules. Before any new capital raise of $200,000–$400,000 can proceed, this structural problem must be resolved.

Four practical pathways exist: converting to an unlisted public company, converting to a distributing co-operative under Victorian law, using crowd-sourced funding via a licensed intermediary, or a hybrid approach. Of these, conversion to a distributing co-operative under the Co-operatives National Law (Victoria) is the strongest fit for a community-owned LGBTQ+ venue — it resolves the shareholder cap breach, embeds democratic one-member-one-vote governance, reduces ongoing compliance costs to approximately $3,000–$8,000 per year (versus $10,000–$27,000 for a public company), and enables capital raising from unlimited members without ASIC involvement or a prospectus.

1. The 50 Non-Employee Shareholder Cap

The Rule: Section 113(1)

Section 113(1) of the Corporations Act 2001 (Cth) provides that a company must have no more than 50 non-employee shareholders to remain registered as a proprietary company (AustLII). This is a continuous obligation — not merely a registration requirement.

Counting Rules: Section 113(2)

The following persons are excluded from the 50-person count (AustLII):

Joint holders of a parcel of shares count as one person
Employee shareholders — anyone who is or was an employee of the company (or a subsidiary) at the time they became a shareholder
CSF shareholders — those who acquired shares under a crowd-sourced funding offer

Community members who are neither current nor former employees count toward the cap. A company with approximately 200 community-member shareholders is in clear breach of s 113(1) (Rouse Lawyers; LegalVision/Mondaq).

Consequences of Breach

ASIC Direction to Convert — Section 165

ASIC’s primary enforcement tool is s 165: if satisfied that a proprietary company has contravened s 113, ASIC may direct the company in writing to convert to a public company within 2 months (AustLII). If the company fails to comply, ASIC may unilaterally change the company type by amending the registration record (s 165(3)) — no court order required.

Criminal Penalties — Schedule 3

Provision	Offence	Penalty
s 113(1)	Exceeding the 50-shareholder cap	Up to 1 year imprisonment
s 113(3)	Engaging in prohibited Chapter 6D fundraising activity	20 penalty units (~$6,600) — strict liability
s 165(2)	Failing to comply with ASIC direction to convert	120 penalty units (~$39,600) — strict liability

Penalty unit value: $330 (Commonwealth, 2024). The penalties were increased by the Treasury Laws Amendment (Strengthening Corporate and Financial Sector Penalties) Act 2019 (AustLII — Schedule 3).

Chapter 6 Takeover Regime — Section 606

When any company (including a Pty Ltd) has more than 50 shareholders in total, the Chapter 6 takeover prohibition applies. Section 606 imposes a 20% voting power ceiling on share acquisitions, meaning any transfer that takes a holder above 20% may have been unlawful since the company exceeded 50 shareholders (MPH Lawyers). This is a serious retrospective compliance risk.

2. Fundraising Exemptions Under Chapter 6D

The Pty Ltd Fundraising Restriction — Section 113(3)

Section 113(3) prohibits a proprietary company from engaging in any activity that would require disclosure to investors under Chapter 6D, except for:

Offers to existing shareholders (s 113(3)(a)(i))
Offers to employees (s 113(3)(a)(ii))
A CSF offer (s 113(3)(b))

This is a strict liability offence (s 113(3A)). ASIC takes a broad view: it will refuse lodgement of a disclosure document from a Pty Ltd, seek an injunction, or issue a stop order (ASIC Corporate Finance Update — Issue 3).

Available Exemptions Under Section 708

The following exemptions remove the disclosure obligation under Chapter 6D. Where no disclosure is required, s 113(3) is not triggered — but the s 113(1) shareholder cap still applies separately (Holding Redlich; RCM Lawyers).

Exemption	Section	Key Conditions	Practical Utility for This Company
Small-scale personal offers	s 708(1)	≤20 investors, ≤$2M, rolling 12 months; must be genuine personal offer (not publicly advertised)	Limited — adding 20 new non-employee shareholders would worsen the s 113 breach
Sophisticated investor	s 708(8)	≥$500K investment; or accountant certificate (≥$2.5M net assets / ≥$250K income, within 6 months)	Unlikely for community members
Experienced investor	s 708(10)	Via AFSL licensee; written reasons; investor acknowledgment	Requires AFSL involvement; costly
Professional investor	s 708(11)	AFSL holder, APRA body, listed entity, ≥$10M gross assets	Not applicable to community members
Senior managers	s 708(12)	Senior managers, close relatives, controlled entities	Very narrow

Critical point: The s 708 exemptions do not override or expand the s 113(1) non-employee shareholder cap. A Pty Ltd using the s 708(1) exemption to issue shares to 20 new investors per year will still breach s 113(1) once total non-employee shareholders exceed 50 (AustLII; Sprintlaw).

Interaction Summary

Scenario	s 113(3) Triggered?	Result
Offer to existing shareholders	No (exception)	Permitted
Offer to employees	No (exception)	Permitted
CSF offer	No (exception)	Permitted if CSF-eligible
Offer under s 708 exemption to new non-employees	No (exemption removes disclosure requirement)	Permitted, but s 113(1) cap still applies
Lodge a prospectus	Yes — breached	ASIC will refuse / stop order

3. Prospectus vs Information Memorandum

Prospectus — Regulated Document (Part 6D.2)

A prospectus is a regulated disclosure document under Part 6D.2 of the Corporations Act. It must contain all information investors would reasonably require to make an informed assessment (s 710), be worded “clearly, concisely and effectively” (s 715A), be lodged with ASIC before use (s 718), and is subject to a 7-day exposure period (s 723) (ASIC — Disclosure documents). A Pty Ltd cannot lodge a prospectus (s 113(3)).

Information Memorandum — Unregulated Document

An Information Memorandum (IM) is not a regulated disclosure document. It is a commercial marketing document used for private offers relying on s 708 exemptions (Sprintlaw; LegalVision):

Not defined in the Act and not lodged with ASIC
No mandatory content requirements
No exposure period
Still subject to the prohibition on misleading or deceptive conduct (s 1041H Corporations Act; s 12DA ASIC Act)

Feature	Prospectus	Information Memorandum
Statutory form	Yes (Part 6D.2)	No
ASIC lodgement	Mandatory	Not required
Content requirements	Prescribed by s 710	None (best practice only)
Available to Pty Ltd	No (s 113(3))	Yes (for exempt offers)
Misleading conduct liability	Yes	Yes
ASIC stop order power	Yes (s 739)	No (but injunctions available)

Penalties for Non-Compliant Fundraising

Section 727 prohibits offering securities without a lodged disclosure document unless an exemption applies. In ASIC v Open4Sale Global Ltd (No 2) [2025] FCA 1038, the Federal Court imposed $2.8 million in penalties and 12-year disqualification orders against directors who raised $1.3M from 83 investors using pitch decks without valid exemptions (Addisons).

Relevant ASIC Regulatory Guides

RG 254 — Offering securities under a disclosure document (procedural guidance for Chapter 6D) (ASIC)
RG 228 — Prospectuses: Effective disclosure for retail investors (content guidance)
RG 261 — Crowd-sourced funding: Guide for companies (ASIC)
RG 173 — Disclosure for on-sale of securities — directed at listed companies, not the primary reference for Pty Ltd fundraising (ASIC)

4. Practical Options Compared

Option A: Convert to an Unlisted Public Company (ss 162–164)

Process: Pass a special resolution (≥75% majority) to convert, then lodge Forms 205C and 206 with ASIC (no ASIC fee). ASIC publishes a Gazette notice; one month after, the conversion takes effect and a new certificate is issued (LegalVision; Patricia Holdings).

Timeline: 6–10 weeks.

What it solves: Removes the 50-shareholder cap entirely. Allows unlimited shareholders and enables the s 708(1) small-scale exemption (≤20 new investors, ≤$2M) for the capital raise without a prospectus.

Ongoing obligations: Minimum 3 directors + company secretary; mandatory annual independent audit; annual financial report lodged with ASIC within 4 months; AGM within 5 months of financial year end; related party transaction rules (Chapter 2E); whistleblower policy (Sprintlaw; ASIC).

Cost Item	Amount
ASIC conversion fees	Nil
Legal advice (constitution, compliance)	$3,000–$8,000
ASIC annual review fee	$1,528/year
Annual audit (small entity)	$5,000–$15,000/year
Company secretary / compliance	$3,000–$8,000/year
AGM administration	$1,000–$3,000/year
Estimated ongoing annual cost	$10,000–$27,000

Option B: Convert to a Co-operative Under Victorian Law

Legal basis: Co-operatives National Law (CNL), applied in Victoria by the Co-operatives National Law Application Act 2013 (Vic). Administered by Consumer Affairs Victoria (CAV) as Registrar of Co-operatives (Consumer Affairs Victoria).

Process:

Pre-approval application to CAV via myCAV — proposed name, draft rules, and (for distributing co-ops) a draft disclosure statement. Standard processing: 28 days. Fee: $420.30 (distributing) or $92.50 (non-distributing) (Consumer Affairs Victoria — Fees).
Formation meeting — minimum 5 members present; resolutions to deregister as a corporation and register as a co-operative; disclosure statement approval requires two-thirds majority.
Registration application — lodge via myCAV with declaration of solvency, assets/liabilities statement, evidence of incorporation. Fee: $37.
ASIC deregistration — apply to deregister the Pty Ltd (Form 6010, $50 fee). CAV registers the co-operative on the day of deregistration (Consumer Affairs Victoria — Conversion).

Timeline: 3–5 months.

Key protections: The conversion must not prejudice any right of a member to any shares held. Existing shares must be converted into co-operative shares of equal number and nominal value. The identity of the corporation is preserved.

Capital raising: Member share offers to unlimited members — no ASIC involvement, no prospectus required. ASIC has confirmed it has no regulatory role in co-operative capital raising (BCCM Community Investment Handbook, 2021). A distributing co-operative can pay dividends capped at 10% above the 5-year bank deposit rate. Member loans (as used by the Castlemaine Community Investment Co-op) are an even simpler mechanism, avoiding Registrar pre-approval entirely.

Cost Item	Amount
Pre-approval fee (distributing)	$420.30
Registration fee	$37
ASIC deregistration	$50
Legal advice (rules, disclosure statement)	$5,000–$15,000
Annual report fee (small co-op)	$92.50/year
Accounting	$3,000–$8,000/year
Annual audit	Not required for small co-ops
Estimated ongoing annual cost	$3,000–$8,000

Small co-operative threshold: Revenue < $8M, gross assets < $4M, employees < 30 (2 of 3). Small co-operatives have no mandatory audit unless the Registrar or 5% of members request one (Consumer Affairs Victoria — Responsibilities).

Option C: Crowd-Sourced Funding (CSF) via Intermediary (Part 6D.3A)

Legal basis: Part 6D.3A of the Corporations Act 2001, inserted by the Corporations Amendment (Crowd-sourced Funding) Act 2017 and extended to Pty Ltd companies by the Corporations Amendment (Crowd-Sourced Funding for Proprietary Companies) Act 2018 (ASIC — CSF).

Critical blocker: The company’s existing ~200 non-employee shareholders already breach s 113(1). CSF shareholders (newly issued under a CSF offer) are excluded from the 50-person cap, but pre-existing shareholders are not. The company would likely need to convert to a public company first before conducting a CSF offer — or seek legal advice on restructuring the shareholder register (Hall & Wilcox).

Eligibility (s 738H): Unlisted; consolidated gross assets and revenue each < $25M; majority of directors resident in Australia; principal place of business in Australia.

Key rules:

Feature	Detail
Issuer cap	$5M in any 12-month period
Retail investor cap	$10,000 per company per intermediary per 12 months
Securities type	Fully-paid ordinary shares only
Cooling-off period	5 business days

Platform fees (Birchal, market leader): EOI fee $2,000 + administration fee $5,000 + success fee 8% (< $500K) / 6% ($500K–$1M) / 5% (> $1M). For a $300K raise: approximately $31,000 in platform fees before legal costs (Birchal). Total estimated cost including legal/accounting: $40,000–$62,000, netting approximately $238,000–$260,000.

Timeline: 10–12 weeks for the CSF offer itself (plus time to resolve the shareholder problem first).

Post-CSF obligations: Annual financial and directors’ reports; audit only if cumulative CSF raises exceed $3M; related party transaction rules apply (ASIC RG 261).

Australia has no standalone “community shares” legislation equivalent to the UK model. The Business Council of Co-operatives and Mutuals (BCCM) has confirmed this gap and developed a Community Investment Handbook (2021) adapting the UK approach to the Australian co-operative framework. The functional Australian equivalent is a distributing co-operative member share offer under the CNL — effectively the same as Option B.

ASIC confirmed in 2016 that it has no regulatory role in co-operative capital raising, and the CSF equity crowdfunding laws have no impact on co-operatives (BCCM).

Comparison Table

Criterion	Unlisted Public Co.	Co-operative (Vic CNL)	CSF via Platform	Community Share Model
Solves 200-shareholder breach?	Yes — no cap	Yes — unlimited members	Partially (new CSF shareholders exempt; existing 200 remain a problem)	Yes — unlimited members
Prospectus required?	Only if > 20 new investors	No	CSF offer document (lighter)	No
Conversion timeline	6–10 weeks	3–5 months	Must fix shareholder issue first	3–5 months
One-time conversion cost	$3,000–$8,000	$5,600–$15,600	Nil (but platform fees apply)	Same as co-op
Capital raise cost ($300K)	$3K–$8K (legal only, s 708)	$420 (Registrar fee)	~$31K–$39K platform fees	$420 (Registrar fee)
Annual ASIC/Registrar fee	$1,528	$92.50	$329–$1,528	$92.50
Mandatory annual audit?	Yes	No (small co-op)	No (< $3M cumulative CSF)	No (small co-op)
Ongoing annual compliance	$10,000–$27,000	$3,000–$8,000	$5,000–$15,000	$3,000–$8,000
Democratic governance?	No (proportional voting)	Yes (1 member, 1 vote)	No	Yes (1 member, 1 vote)
Capital growth for investors?	Yes	No (fixed-price shares)	Yes	No (fixed-price shares)
Community mission alignment	Low	Very high	Medium	Very high

5. Australian Precedents for Community-Owned Hospitality Venues

All successful Australian precedents use the distributing co-operative model, not a Pty Ltd structure.

Sea Lake Hotel Co-operative Limited (Victoria)

The Royal Hotel in Sea Lake (north-west Victoria) was condemned and at risk of demolition when locals organised a community buyout in 2017. A two-entity structure was used: a company owns the hotel building (freehold) and a distributing co-operative operates the business. Member shares are issued at $1 nominal value with a $5,000 minimum subscription. No member may hold more than 20% of issued share capital. A formal Disclosure Statement was approved by the Registrar of Co-operatives. Governance is one member, one vote — active membership requires $100 minimum purchase of goods/services annually (BCCM — Sea Lake Disclosure Statement; Co-operative Farming).

Lockington Community Hotel Cooperative (Victoria)

Lockington (population ~800, northern Victoria) raised $600,000 from 96 shareholders in $5,000 lots to purchase and operate the local pub, which had closed twice before. Formed in 2019–2020 as a community co-operative with democratic governance (ABC News, 2020).

Castlemaine Community Investment Co-operative (Victoria)

The most innovative recent precedent. In 2024, the Castlemaine community raised $1.95 million from 300+ members entirely without bank financing. Capital was raised as member loans at fixed interest rates of 0–4% (not share capital), avoiding Registrar pre-approval requirements for share disclosure statements. One anonymous donor contributed $100,000. Membership fee: $40/year. This approach demonstrates that member loans are a faster and more flexible capital-raising mechanism than formal share issues (ABC News, December 2025).

Hotel Theodore Co-operative Association (Queensland)

Queensland’s only community-owned pub, established in 1950 via a special Act of Parliament (Theodore Co-Operative Hotel Association Enabling Act). At peak, 168 shareholders held 25-cent shares with a 40km residency requirement. It entered voluntary administration in 2023 after five years of financial difficulty — a cautionary example about the challenges of sustaining community-owned hospitality businesses (ABC News, August 2023).

LGBTQ+ Venue Precedents

No Australian precedent exists for a community share offer or co-operative specifically structured around an LGBTQ+ venue. The Stonewall Hotel (Sydney) was acquired by US-listed Pride Holdings Group for $9.2M in company stock (not a community share offer) and subsequently entered voluntary administration in March 2026 (Gay Sydney News; ABC News, March 2026). Beat Magazine has covered the UK community ownership model as a potential solution for Melbourne’s struggling music venues but no completed transaction has been documented for a Melbourne LGBTQ+ venue (Beat Magazine, April 2025).

International comparators: The Exchange (Bristol, UK) raised £300,000 from 400+ investors in 2018 as a community-owned live music venue. Music Venue Properties (UK) raised £2.35 million from ~1,250 investors in a 2022 community share offer to purchase grassroots venue freeholds (Co-operative News).

A successful community share offer for an LGBTQ+ venue in Melbourne would be a first of its kind in Australia.

6. Victorian Co-operatives National Law: Conversion & Ongoing Compliance

The Mutualisation Process

Converting a Pty Ltd to a co-operative under the CNL follows four steps (Consumer Affairs Victoria):

Step	Action	Timeline	Fee
1	Pre-approval application to CAV (name, rules, disclosure statement)	28 days processing	$420.30 (distributing)
2	Formation meeting (≥5 members; 2/3 majority for disclosure statement)	1–2 weeks after approval	—
3	Registration application via myCAV	1–2 weeks processing	$37
4	ASIC deregistration of Pty Ltd; CAV registers co-op same day	2–4 weeks	$50
Total		3–5 months	~$507 (plus legal)

Shareholder Rights Protection

The CNL provides that the conversion must not prejudice any right of a member to any shares held. Existing shareholders receive co-operative shares of equal number and nominal value to their existing company shares. The identity of the corporation is preserved — it is a transfer of form, not the creation of a new entity.

The key change for investors is that co-operative shares have fixed nominal value with no capital appreciation. Returns come through dividends (distributing co-ops), rebates, and the social value of the venue.

Types of Co-operatives

Feature	Distributing	Non-Distributing
Surplus distribution	May pay dividends, rebates, bonus shares	Must apply surplus to activities
Share capital	Must have share capital	Optional
Minimum members	≥5 active members	≥5 active members
Share cap per member	No member may hold > 20% of issued shares	Same
Voting	One member, one vote	One member, one vote
Disclosure statement	Required for formation and share issues	Not required unless directed
Suitability	Best if community investors want financial returns	Best for pure community organisations

Consumer Affairs Victoria states that non-distributing co-operatives are “more appropriate for a community organisation,” but a distributing co-operative is more appropriate if community investors expect financial returns (Consumer Affairs Victoria).

Capital Raising Instruments Under the CNL

Co-operatives have access to several capital instruments (BAL Lawyers):

Member shares: Only members; fixed nominal value; no member > 20% of issued capital; Registrar pre-approval of disclosure statement required (distributing co-ops); no limit on total members or capital raised; ASIC has no role
Co-operative Capital Units (CCUs): Hybrid security; no voting rights; can be issued to members and non-members; requires Registrar pre-approval + special resolution; for non-members, Corporations Act disclosure applies
Debentures: Members and non-members; Corporations Act applies for non-member issues
Member loans: Voluntary loans at agreed interest rates (0–4% as used by Castlemaine); avoids Registrar pre-approval requirements; simplest mechanism

For a $200K–$400K raise with 200 existing members each investing $1,000–$2,000, a member share offer is readily achievable without ASIC involvement.

Ongoing Compliance: Co-operative vs Public Company

Obligation	Small Co-operative	Unlisted Public Company
Regulator	Consumer Affairs Victoria	ASIC
Annual fee	$92.50	$1,528
Financial statements	Prepared for members (not lodged with regulator)	Lodged with ASIC within 4 months
Mandatory audit	No (unless directed by Registrar or 5% of members)	Yes
AGM	Yes (within 5 months of year end)	Yes (within 5 months of year end)
Minimum directors	Rules determine	3 (at least 2 Australian resident)
Company secretary	Not required	Required
Annual compliance cost	$3,000–$8,000	$10,000–$27,000

7. ASIC Filing Obligations for a Pty Ltd with 200 Shareholders

Current Obligations (as a Small Proprietary Company)

Under s 45A, a proprietary company is “large” only if it meets 2 of 3 thresholds: consolidated revenue ≥ $50M, consolidated gross assets ≥ $25M, or ≥ 100 employees. A community venue is almost certainly a small proprietary company (AustLII; Finlaysons).

Obligation	Requirement	Section
Annual review fee	$329/year	ASIC annual review
Annual company statement	Confirm details annually	s 345A
Solvency resolution	Within 2 months of review date	s 347A
Share issue notification (Form 484)	Within 28 days of each issue	s 254X
Officeholder/address changes (Form 484)	Within 28 days	Various
Financial records	Keep adequate written records	s 286
Financial reports to ASIC	Not required (small proprietary)	s 45A
AGM	Not required	—
Audit	Not required unless directed	—

Every share issue must be notified to ASIC via Form 484 within 28 days, including the date of issue, number and class of shares, and amount paid (ASIC — Share Issues). Failure to lodge carries a penalty of 5 penalty units (~$1,565) per breach (Doogue + George). For each past share issue that was not notified, the company has a separate breach.

Changes to the top 20 members of any share class must also be notified via Form 484, Section C4 (s 178B).

What Happens if ASIC Discovers the Breach

ASIC’s enforcement approach for small proprietary companies involves some discretion. INFO 208 notes that matters in small proprietary companies are “unlikely to satisfy” ASIC’s public interest test for enforcement — providing some comfort but no guarantee (ASIC — INFO 208). However, ASIC has been increasing data analytics to identify breaches and has included financial reporting misconduct among its 2026 enforcement priorities (Rouse Lawyers).

If ASIC discovers the breach, the likely sequence is:

ASIC issues a written direction to convert to a public company within 2 months (s 165(1))
If the company does not comply, ASIC unilaterally changes the company type by amending the register (s 165(3))
A new certificate of registration is issued as a public company limited by shares
The company immediately becomes subject to all public company obligations (3 directors, secretary, audited financials, AGM)

Immediate Actions the Company Should Take

Audit the shareholder register — determine how many are genuinely non-employee shareholders (employee and CSF shareholders are excluded from the count)
Review all past share issues — confirm Form 484 was lodged within 28 days of each issue
Check s 606 takeover compliance — confirm no share transfer has taken a shareholder above 20% voting power since the company exceeded 50 shareholders
Seek legal advice on the s 113 breach — voluntary disclosure to ASIC may reduce enforcement risk
Begin conversion planning — either to a public company or a co-operative

Conclusion and Recommended Pathway

The company faces a compound regulatory problem: ongoing breach of s 113(1), potential s 254X notification breaches for past share issues, and possible s 606 takeover exposure. Any new capital raise of $200K–$400K must be preceded by structural reform.

Recommended: Convert to a Distributing Co-operative

For a community-owned LGBTQ+ venue with democratic ownership values, converting to a distributing co-operative under the Co-operatives National Law (Victoria) is the strongest path. It:

Resolves the s 113 shareholder cap breach permanently
Embeds one-member-one-vote democratic governance
Enables unlimited member share offers without ASIC involvement or a prospectus
Reduces ongoing compliance costs by approximately $7,000–$19,000 per year compared to a public company
Transfers regulatory oversight from ASIC to Consumer Affairs Victoria (lighter touch)
Has proven Victorian precedents in community-owned hospitality (Sea Lake, Lockington, Castlemaine)
Allows dividends from surplus to community investor-members

The main trade-off is the loss of capital appreciation on shares (co-operative shares are fixed-price) and a longer conversion timeline (3–5 months vs 6–10 weeks for public company conversion).

Alternative: Public Company + CSF Offer

If the community prefers a capital-appreciating share structure with broader investor reach, conversion to an unlisted public company followed by a CSF offer via Birchal is the most practical capital-raising alternative. However, the annual compliance burden ($10,000–$27,000) and mandatory audit make this a significantly more expensive ongoing proposition for a small community venue.

Immediate Priority

Regardless of which pathway is chosen, the company should immediately obtain legal advice on the s 113 breach, audit its shareholder register, and review compliance with Form 484 notification obligations for past share issues. The s 606 takeover exposure should also be assessed. This is not a matter that can wait for the capital raise decision.

This report is for informational purposes only and does not constitute legal advice. All legislative references are to the Corporations Act 2001 (Cth) and the Co-operatives National Law (Victoria) as applied by the Co-operatives National Law Application Act 2013 (Vic), current as at April 2026. The company should obtain independent legal and accounting advice before making structural or fundraising decisions.

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