by Staff of the Firm | Nov 21, 2015 | Avoiding Investment Scams, Securities Laws, Uncategorized
In re Sand Hill Exchange. In re Sand Hill Exchange involved two Silicon Valley entrepreneurs, Gerrit Hall and Elaine Ou, who operated a website called Sand Hill Exchange (“Sand Hill”).[1] The SEC said that the two wanted to create a business that would involve valuing...
by Staff of the Firm | Nov 12, 2015 | JOBS Act, Private Placements, Raising Capital, Securities Laws, Uncategorized
Intrastate Exemption. We briefly touched on the concept of intrastate exemption in our previous blog series on crowdfunding (available here). As the name suggests, intrastate offerings are transactions that do not involve interstate commerce (hence the exemption, as...
by Staff of the Firm | Nov 10, 2015 | Avoiding Investment Scams, Securities Laws, Uncategorized
On June 17, 2015, the Securities and Exchange Commission (“SEC”) issued an investor alert to warn investors about fantasy stock trading and other similar websites. For a full text of the alert, click here. Although most people think that terms like “swap,”...
by Staff of the Firm | Nov 5, 2015 | JOBS Act, Private Placements, Raising Capital, Securities Laws, Uncategorized
General Solicitation. As we discussed in our previous blog series on exempt offerings (available here), absence of general solicitation is a condition to be met in most exempt offerings, with limited exceptions, such as offering under Rule 506(c). This is important...
by Staff of the Firm | Oct 31, 2015 | JOBS Act, Private Placements, Raising Capital, Securities Laws, Uncategorized
Verification of Accredited Investor Status. The next set of questions are related to the requirement under Rule 506(c) that an issuer take reasonable steps to verify, and form a reasonable belief regarding, the accredited investor status of a purchaser at the time of...
