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Pitch Perfect: Demo Days, General Solicitation and the HALOS Act of 2025

Your company is invited by a local meetup group to present at demo day with other startups, and you accept.  The group announces the demo day lineup of startups in an e-blast, on its website, on its Facebook page and through...more

(Minimum Investment) Size Matters, When it Comes to Rule 506(c) Verification

Before 2013, issuers were prohibited from using any means of general solicitation or advertising when raising capital in the private markets.  The prohibition was perceived by many to be the single biggest impediment to...more

Crypto Collectibles: Meme Coins Deemed Not Securities by SEC Staff

According to crypto platform Kraken, the aggregate market cap for all meme coins is over $70 billion.  Five meme coins would be considered unicorns (market cap over $1 billion) if they were startups.  Dogecoin’s market cap is...more

Making Finders Keepers: Unregistered Broker-Dealers and the Need for Reform

Identifying potential investors is one of the most difficult challenges facing early-stage companies.  The range of amounts sought at this stage is typically greater than what could be provided by the founders and friends and...more

SEC’s First Two NFT Enforcement Actions Cast Shadow of Ambiguity

The Securities and Exchange Commission recently brought its first two enforcement actions against issuers of non-fungible tokens (NFTs), resulting in cease-and-desist orders, penalties and other remedies, finding that the...more

Parting the Crypto Sea: Ripple’s XRP Ruled to be a Security When Sold to Private Investors, But Not When Sold on an Exchange

Judge Analisa Torres’ greatly anticipated Order in the SEC’s lawsuit against Ripple is a split decision.  The Order basically finds that Ripple’s digital token XRP is a security when sold privately to individuals and...more

Passive Aggressive: Unpacking Elon Musk’s Beneficial Ownership Filings Regarding Twitter, Inc.

Elon Musk’s contentious relationship with the Securities and Exchange Commission is likely to become even more complicated as a result of Mr. Musk’s filings with the Commission to report his recent purchases of shares in...more

Protecting the Protected: SEC Proposes New Safeguards for Private Fund Investors

The Securities and Exchange Commission just proposed new rules to protect investors in private investment funds. The proposed rules would require private fund advisers to disclose certain information and avoid certain...more

Comments from the SEC(nut) Gallery: SEC Comment Letters Focus on SPAC Conflicts of Interest

Ever since the SPAC market exploded in late 2020 and early 2021, the SEC has sounded alarm bells through investor alerts, staff statements and public comments.  In March of 2021, it warned investors not to invest in SPACs...more

“Do Your Homework!”: SEC Order Sends Strong Message to SPAC Participants on Due Diligence

The Securities and Exchange Commission announced on July 13, 2021 that it settled fraud charges against a special purpose acquisition company, its sponsor, its sponsor’s CEO and its proposed merger target for making...more

Securities Safety Check for New TV Series “Unicorn Hunters”

A new reality streaming television series called Unicorn Hunters debuted last week in which startups will pitch to a panel that includes Apple co-founder Steve Wozniak, and the panelists after some grilling of the...more

Issuers May “Test-the-Waters” Before Choosing a Securities Exemption

Perhaps the most vexing threshold issue faced by any company considering a capital raise is which securities exemption to pursue.  The chosen exemption largely depends on the targeted amount of the raise, as well as the...more

Relief for Pre-Verified Accredited Investors May Encourage Rule 506(c) Offerings

It’s pretty common for issuers in follow-on offerings to solicit investors from previous rounds first.  Indeed, doing so is often mandatory when early investors have preemptive rights. ...more

Why Private Capital and Crowdfunding Markets Should be Nervous about President Biden’s Regulatory Freeze

A freeze on government regulation is generally perceived by most people as being a positive development for private enterprise.  Not necessarily so, however, when the regulation being frozen is itself a reform of preexisting...more

“Demo Days are Here Again”: Part Two of Exempt Offering Amendments Deeper Dive

At the 1932 Democratic National Convention, the live band at one point burst into “Happy Days are Here Again”, FDR’s favorite, drawing raucous cheers from convention delegates.  It went on to become the Democratic Party’s...more

Exempt Offering Amendments Deeper Dive, Part One: Higher Offering Caps

Last month, The Securities and Exchange Commission passed sweeping reforms of the rules governing exempt offerings (the “2020 Reforms”) to make it easier for issuers to move from one exemption to another, to bring clarity and...more

Significant Exempt Offering Rule Reforms Approved by SEC to Facilitate Capital Formation

On November 2, 2020, the SEC adopted significant rule amendments to simplify, harmonize and improve the exempt offering framework to facilitate capital formation and investment opportunities in startups and emerging...more

SEC Proposes Much Needed Finder Exemption, and Paul Anka Must Be Singing

Finders play a vital role in introducing startups to potential investors.  Yet the general requirement that persons soliciting investors must register with the Securities and Exchange Commission as broker-dealers and be...more

Private Market Investing Not Just for the Wealthy Anymore?

The Securities Exchange Commission expanded the definition of “accredited investor” by adding new categories of investors that have sufficient investment knowledge and expertise to participate in private investment...more

COVID-19 SEC Filing Relief and Disclosure Guidance

Public companies stressing over how to meet filing deadlines during the COVID-19 crisis and what to say about the pandemic’s impact just received a filing reprieve and disclosure guidance from the SEC. The Securities and...more

Proposed Three-Year Digital Token Safe Harbor May Bridge Gap to Decentralization or Functionality

It’s not often that an SEC Commissioner quotes Bruce Springsteen – not once, but twice – in a speech on securities regulation. But SEC Commissioner Hester Peirce did just that in a February 6, 2020 speech in which she...more

First Qualified Regulation A Token Offering: Will “$2 Million Contribution to Crypto Industry” be Precedent Setting?

On July 10, 2019, the Securities and Exchange Commission declared Blockstack PBC’s offering statement “qualified”, thus allowing Blockstack to commence the distribution and sale of its Stacks Tokens under Regulation A. ...more

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