01
Initial conversation
A direct call. What are you raising or selling, on what timetable, and who is already involved. We will tell you in that conversation whether this is work the firm should take on, and if it isn't, we'll say why.
Five things,
done properly.
Registered broker-dealers declare the activities they conduct and are supervised against that declaration. What follows is our list — not a menu written by a marketing department.
01 — Capital raising
Private placements
of securities
Placing unregistered offerings for issuers who need capital without the cost, disclosure burden or timetable of a public raise. In practice this is Regulation D work: the offering is structured, the documents are assembled, and interests are placed with investors who genuinely qualify.
The firm's role is to run that process correctly — confirming accreditation, controlling the distribution of offering materials, documenting suitability for each subscriber, and making sure the issuer understands what it is signing. It is unglamorous work and it is where placements go wrong.
Typically involves
- Regulation D offerings to accredited investors
- Offering-document review and control
- Accreditation and suitability verification
- Investor identification and placement
- Subscription processing and closing support
Typically involves
- Single-asset and portfolio syndications
- Sponsor and partnership structuring
- Investor group assembly
- Texas and Gulf Coast property
- Ongoing investor reporting support
02 — Real property
Real estate
syndication
Bringing investor groups together around individual properties and property partnerships. The firm is registered as a real estate syndicator and has been doing this kind of work through the whole of Houston's modern history.
Houston has run hot and cold more times than almost any American market — 1982, 1986, 1998, 2008, 2015, 2020. A syndicator that was present for all of them has a different sense of downside than one that started after the last recovery.
03 — Primary distribution
Limited partnership
interests
Selling limited partnership interests and comparable programs in primary distribution. This is one of the firm's founding disciplines and remains on its registration.
Programs of this kind carry long holding periods, limited or no secondary market, and tax characteristics that vary materially between investors. The firm does not treat them as a product to be distributed; each subscription is assessed against the individual investor's circumstances, and a great many are declined.
Investor should understand
- Interests are illiquid and long-dated
- There may be no secondary market at all
- Distributions are not guaranteed
- Tax treatment is investor-specific
- Total loss of capital is possible
Firm capital
Separate from all client activity
04 — Own account
Trading securities
for our own account
The firm trades on a proprietary basis using its own capital. This is disclosed on its registration as a distinct line of business, and it is kept structurally separate from any client engagement.
Proprietary activity is stated here for completeness rather than as an offering. No client funds are involved, no client is a counterparty to it, and it creates no obligation to any investor.
05 — Advisory
Merger & acquisition
consulting
Advisory work for privately held companies weighing a sale, an acquisition or a recapitalisation. The firm is registered to provide consulting services related to mergers and acquisitions and takes a small number of these engagements at a time.
The value in a lower-middle-market process is rarely the auction mechanics. It is knowing which three counterparties are actually serious, what a defensible valuation looks like in the current market, and where a deal is likely to break during diligence — so it can be dealt with in week two rather than week twelve.
Typically involves
- Sale readiness and valuation perspective
- Counterparty identification and approach
- Transaction structuring input
- Diligence coordination
- Support through to closing
How an engagement runs
Four stages.
Most enquiries
end at the first.
That is not a failure of the process — it is the process. A firm this size protects its record by being decisive about what it declines.
02
Review & scope
Documents, structure and the regulatory shape of the transaction get examined before anything is agreed. Engagement terms, scope and compensation are set out in writing at this point — never later.
03
Execution
Placement, syndication or advisory work proceeds with the compliance file built alongside it rather than reconstructed afterwards. Suitability, accreditation and document control are handled as the transaction moves, not at the close.
04
After closing
Records are retained as required, and the firm stays reachable. In private markets the relationship generally outlasts the transaction — the second and third deals are the ones that matter.
Before you call
Questions worth
asking any
broker-dealer.
No. Commerce Securities Corporation does not hold or maintain customer funds or securities and does not provide clearing services for other broker-dealers. Funds in a transaction move directly between the parties to it.
No. The firm is registered as a broker-dealer, not as an investment adviser. It does not manage portfolios, does not offer discretionary accounts, and does not provide investment advisory, tax or legal advice. If you need advisory services, you should engage a registered investment adviser separately.
Private placements are generally restricted to investors who qualify as accredited under Regulation D of the Securities Act of 1933, and are further limited by the terms of each individual offering. Qualifying financially is a threshold, not a recommendation — suitability is assessed separately for every subscriber.
They are speculative and illiquid. There is usually no secondary market, holding periods are long and often indeterminate, distributions are never guaranteed, valuations are not independently quoted, and the entire amount invested can be lost. Read the offering documents in full before subscribing to anything.
Search FINRA BrokerCheck for CRD #10806. The report shows the firm's registrations, approved lines of business, direct owners and executive officers, and every reported disclosure event in its history. Individual registered persons can be searched by name or CRD number in the same system.
The firm is registered with the SEC, is a FINRA member, and holds state registrations in Texas and California. Securities business is transacted only where the firm and the relevant registered person are properly registered or exempt.
Bring us the deal
you're not sure
anyone will take.
One call is usually enough for both sides to know whether there is anything here. There is no charge for finding out and no follow-up sequence if the answer is no.