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No Action Letter – Regulation D Rule 506(c)

The SEC now permits public marketing of private placements, without burdensome investor wealth verification requirements, if the investment is big enough. On March 12, 2025, the U.S. Securities and Exchange Commission (SEC)...more

A Summary of Certain Recent Enforcement and Non-Enforcement Actions

Sender Primary Liability for Misstatements in PPMs and Prospectuses: Lorenzo v. SEC (No. 17-1077 -- U.S. – 2019). On March 27th, the Supreme Court issued a 1934 Act Rule 10b-5 opinion that will have implications for...more

Fund Manager Briefing: Briefing and Capital Raising in Europe

March 29th is Brexit Day unless extended. While extension is what the UK Parliament has voted for, the EU approval process and the length of the extension (If any) remains to be seen. Faced with this uncertainty as to when...more

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement - The EB-5 Immigrant Investor Program has Provided a Breeding Ground for Securities Fraud - Back in 1990, Congress created the United States Citizenship and Immigration Services (USCIS) EB-5...more

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