your right. Bergamo wouldn't be registered with FINRA, it would be the broker/dealer they bought out who would have to be regitered.
"Private Placement has to be done by FINRA and SEC Registered Firms, even though its 504(D) there are still very strict regulations to follow, paperwork to file with SEC an FINRA, if the Private Placement is not registered with both agencies, then it is a outright fraud."