Under Regulation crowdfunding, an intermediary is required to deny access to its platform if the intermediary has a reasonable basis for believing that an issuer or its covered persons is subject to a “Bad Actor” disqualification. To satisfy this requirement, the intermediary must conduct a background and securities enforcement regulatory check on the issuer and its covered persons. The SEC does not provide guidance on the content of the required background and securities enforcement regulatory history checks beyond what is necessary to establish a reasonable basis for believing that no disqualifying events are present.