- David Duccini
Silicon Prairie Capital Partners
Greater Minneapolis-St. Paul Area, MN
Entrepreneur and Change Agent. Top Five Strengths: Ideation, Activator, Strategic, Intellection, Learner.
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Entrepreneur and Change Agent.
Top Five Strengths: Ideation, Activator, Strategic, Intellection, Learner.
Myers-Briggs Type Indicator (MBTI): ENTP, "Inventor"
Insights Discovery: "23: Motivating Director (Classic)"
Specialties: New Product & Business Development, Knowledge Management & Transfer, Enterprise Architecture, Information Risk Management
Passions: Flying. Diving. Brewing.
Sometimes found on Freenode as LittleDuke or TheLittleDuke
Silicon Prairie Capital Partners
April 2020 - present
A modern investment bank inspired by investment crowdfunding and powered by automation.
"There will never be an end for the need to raise capital just as there will never be an end to deploy it profitably."*
Our firm can help you convert your social capital into financial capital. You no longer have to try and beg a VC or Angel Investor to validate your Big Idea when you can raise unlimited amounts of capital in an "Initial Crowd Offering" using our proven platform.
Join us any Friday for our open office hours meetup: https://www.meetup.com/Silicon-Prairie-Investing/
"The Silicon Prairie: Where Good Ideas Grow!"
* sounds more impressive in Latin
Founder & CEO
Company NameSilicon Prairie Portal & Exchange, llc d/b/a Silicon Prairie Online
October 2016 - present
The kickass regulation crowdfunding portal operator registered with the SEC & FINRA to offer REG-CF crowdfunding nationally as well as in Minnesota under MNvest, Wisconsin, Iowa and Michigan.
We offer blockchain based solutions to JOBS act crowdfunding issuers and stakeholders to solve three core problems every business has:
1. Authentic investor communications
2. Voting, recorded on a distributed ledger
3. Liquidity! First on a hosted Alternative Trading System and then peer-to-peer.
Every Friday from 9:30 to noon central we host a virtual "Open Office Hours / AMA + Investment Crowdfunding 101 Presentation"
Information and links to our videos plus registration can be found here: https://www.meetup.com/Silicon-Prairie-Investing/
David Duccini replied:
TLDR; "Fees & Fines"
FINRA is a purportedly not-for-profit membership based organization but their Revenue and Expenses are not easily discernible, at least not in public sources like CharityNavigator:
FINRA likely generates the vast majority of its income from membership fee's that include a percentage of funds placed through the member firm. It's easy to guess that Goldman Sachs is the largest contributor here and your average funding portal is not.
We could probably get a good guesstimate based on the number of member firms, states registered in, and the public bragging FINRA does about the fines it levies, though the vast majority of those fines are likely procedurally levied and privately not disclosed unless you scoured the public accounting of the member firms and see if they reported them in their expenses.
FINRA also manages the Central Registration Depository or CRD (aka brokercheck) and likely gets some funding from federal and state regulators to prop it up. Ironically the OTC reporting facility is managed by NASDAQ, thus forcing firms to pay a minimum of $500/month to a "competitor" for the privilege of supplying trade data to FINRA.
Expenses could also likely be surmised based on the number of locations
likely rents and on the number of employees (3,600) and the average salary information which is disclosed in their rotating job posts that constantly need filling due to the high turn over rates. See Glassdoor for former employee sentiment:
With the year over year decline for over a decade in the number of registered reps and broker-dealers it is just a matter of time before the organization will be forced to downsize, as it is now there are more employees at FINRA than there are firms to monitor:
Your average funding portal contributes about $2,200 per year and napkin math based on the number of registered portals in good standing suggests that they probably all combined contribute a maximum of $250,000 year to the top line -- even if we generously doubled it to $500K it is clear that funding portal operations is likely losing money for the organization based on the composition and likely compensation of that group.
It is certainly true of the vast majority of broker-dealers of which some numbers suggest that up to 90% of the membership base are "small member firms" which has lead some current and former members suggesting that you'll get better treatment at your DMV than you will as an average member firm.
Most of the problems FINRA has it creates for itself, and could likely be solved with two simple changes to their operating and membership agreements:
1. Provide Model Documents for their member firms, and
2. Establish Service Level Agreements
Things I have long publicly advocated.
There is certainly room for a competitor SRO in the US, and one likely based on a cooperative model where the actual costs of operations are disclosed and fee's apportioned to members based on actual usage. Your local power company, for example, is ALSO a licensed monopoly but must obtain approval from the granting authority to set or raise rates.
At the end of the day, the SEC cannot simply offer us "choice" in the form of "do you want it or not" -- especially given the arbitrary and capricious manner in which FINRA unequally enforces the rules. The two items I called out above would go a long way to curing that and improving member relations.
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