--- title: "Rainmaker and Moran: roles and separate regulatory history" language: en canonical: https://osint.v3rta.com/dossiers/linqto/rainmaker-and-moran/ as_of: 2026-10-09 keywords: ["Linqto","Liquidshares","Linqto Capital","private market investments","series interests","Chapter 11","customer recovery plan","Sandton financing","Forge trustee dispute","corporate governance","securities proceedings"] --- # Rainmaker and Moran: roles and separate regulatory history - Also known as: Rainmaker Securities, LLC - Jurisdiction: US (US) - FINRA firm CRD: 132995 - U.S. Securities and Exchange Commission broker-dealer file: 8-66667 **Question.** Which supervisory allegations and sanctions belong to which matter? **Answer.** Rainmaker’s alleged Linqto supervision differs from its historical settlements. Moran’s StartEngine FinOP sanction is a separate proceeding. ## Linqto roles and corporate identity - Analysis: The customer complaint alleges that Rainmaker provided paid supervisory services and that Endoso received sales commissions. Those are pleaded allegations, rather than a finding that Rainmaker controlled the platform. The August 2022 Form D separately lists Rainmaker's fee arrangement while recording zero numeric commissions and saying registered representatives were not directly compensated. A compensation-section entry alone does not establish a personal payment to Endoso. These civil role and commission allegations are separate from Endoso’s later guilty plea and do not establish another defendant’s liability. [s-d147] [s-d16] - Attributed: The complaint identifies Rainmaker as a FINRA-registered broker-dealer and SIPC member based in Miami and alleges it provided paid supervisory services to Linqto. [s-d147] - Qualification: Paid oversight is alleged in the complaint and does not show Rainmaker controlled every Linqto activity. - Analysis: Rainmaker's regulatory report identifies Rainmaker Group Holdings as its sole member. It describes that holding company as 100% owner of the securities firm, with Glen Anderson and Greg Martin each owning more than 25% of the holding company. A separately mentioned entity, RCM, has a 50/50 ownership description; that percentage cannot replace the holding-company bands. [s-d247] - Analysis: Moran's regulatory employment history lists Parent chief compliance officer from November 2021 to August 2024, Capital consultant from May 2021 to December 2024 and Investment Management adviser representative from March 2022 to September 2023. Employment and registration periods are distinct, and the complaint uses a different period for his Parent compliance office. The discrepancy is preserved rather than resolved by merging the dates. [s-d248] [s-d147] - Attributed: The civil complaint alleges Brian Moran was Linqto chief compliance officer from November 2021 to December 2024 and affiliated with Capital from December 2022 to December 2024. [s-d147] - Qualification: The role dates are alleged in the civil complaint; they are not an adjudication of the complaint's substantive claims. - Analysis: Rainmaker's regulatory snapshot lists the putative securities class action as pending, filed November 17, 2025 and served January 19, 2026. Its indexed and partly extracted disclosure does not establish a later merits judgment or settlement. The customer-litigation page places the supervisory allegations in their wider pleading context. [s-d247] ## Moran’s separate StartEngine resolution - Analysis: FINRA's October 9, 2025 settlement concerned Moran's financial-and-operations role at StartEngine Primary, rather than Linqto. Without admitting or denying findings, he consented to findings that backdated resolutions produced inaccurate capital reports, operations fell below required net capital on 45 days with deficits up to about $2 million, and customer-reserve deficits reached about $220,000. The retained PDF has OCR and partial-page limitations. [s-d248] [s-d324] - Analysis: The resolution imposed a $10,000 fine, a suspension from FinOP functions from November 3, 2025 to February 2, 2026 and examination requalification. This was a capacity-specific suspension, rather than a general industry ban. A requalification condition marked unsatisfied in the retained snapshot does not establish his subsequent compliance status. [s-d248] ## Rainmaker’s historical resolutions - Analysis: The July 15, 2015 FINRA resolution censured Rainmaker and imposed a $125,000 firm fine over private-placement diligence and solicitation. Glen Anderson received a $10,000 fine and a general-securities-principal suspension from August 3 to October 3, 2015. The settlement was accepted without admitting or denying findings. These sanctions concern a separate historical proceeding. [s-d247] - Analysis: The September 2, 2016 Illinois consent resolution imposed a $1,000 firm fine and agreed restitution of $16,125 and $8,875 to two investors concerning supervision of Ten X sales. Rainmaker did not admit wrongdoing in fact or law. The resolution does not establish the later Linqto allegations. [s-d247] - Analysis: The January 10, 2018 FINRA resolution imposed censure, a $30,000 fine and review of customer-information procedures after approximately 60 exempt transactions lacked required customer information. The report records payment of the fine on January 29. Rainmaker accepted the findings without admitting or denying them; this is another distinct historical matter. [s-d247] ## Firm identifiers in the career record - Analysis: The retained FINRA histories identify Cicada Securities by firm CRD 314109, Fundamental Interactions Neutron Direct by CRD 322233, StartEngine Primary by CRD 291773 and EquityBee Securities by CRD 41896. These identify the firms in the historical employment and registration record; they do not extend the StartEngine findings to those other firms. [s-d248] [s-d283] [s-d281] ## Sources - [s-d147] Court record source · s-d147 - [s-d16] Linqto Liquidshares Form D: Alloy series, 2022, U.S. Securities and Exchange Commission EDGAR - [s-d247] FINRA BrokerCheck: Rainmaker Securities, CRD 132995, Financial Industry Regulatory Authority - [s-d248] FINRA BrokerCheck: Brian Michael Moran, CRD 1940341, Financial Industry Regulatory Authority - [s-d324] FINRA disciplinary and other actions reported for December 2025, Financial Industry Regulatory Authority - [s-d283] FINRA BrokerCheck: Spencer Robert Francis, CRD 7118064, Financial Industry Regulatory Authority - [s-d281] FINRA BrokerCheck: Susan Lawson Woodard, CRD 4225106, Financial Industry Regulatory Authority