Banking and Finance

Recent Posts

General Solicitation Restrictions for Private Placement Issuers
Posted on 22 Sep 2015 by Arina Shulga

On August 6, 2015, the Securities and Exchange Commission (the "SEC") issued a number of Compliance and Disclosure Interpretations (" CDIs ") related to the issue of “general solicitation” (or “general advertising”... Read More

Citizen VC No-Action Letter - the SEC Guidance on Online Private Placements
Posted on 17 Sep 2015 by Arina Shulga

As a follow up to my previous blog post where I discussed the new CDIs relating to the definition of "general solicitation" in private offerings conducted under Rule 506(b), I decided to discuss the recently issued SEC no-action letter to Citizen... Read More

Rule 506(d) “Bad Actor” Disqualifications: Who’s a Bad Actor and Why are They Bad? - Part I
Posted on 22 Jul 2015 by Arina Shulga

Rule 506 is by far the most widely used Regulation D exemption for conducting private placements. According to the SEC, about 90-95% of all private placements are conducted pursuant to Rule 506. This Rule permits sales of an unlimited dollar amount of... Read More

Private Placements: What Happens if You Fail to File Form D (or File It Late)?
Posted on 20 Sep 2011 by Alexander Davie

Form D is a document that the SEC requires a company to file when it issues securities in a private placement under Regulation D. It must be filed with the SEC within 15 days of the first sale of a security in a private placement. In addition, for... Read More