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 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...
by Staff of the Firm | Oct 27, 2015 | JOBS Act, Private Placements, Raising Capital, Securities Laws, Uncategorized
On August 6, 2015, the Securities and Exchange Commission (“SEC”) issued Compliance and Disclosure Interpretations (“C&DIs”). For the full text of the C&DIs, click here. C&DIs are not rules, regulations, or statements of the SEC, but reflect the current...