Disclosure Requirements, Securities Regulation, No-Action Letters

SEC Provides Further Clarity in Rule 506(c) Offerings

Mintz - Venture Capital & Emerging Companies... on 4/3/2025

On March 12, 2025, the Securities and Exchange Commission (the “SEC”) issued a No-Action Letter that provided guidance regarding the ways issuers can satisfy the accredited investor verification requirements of offerings made...more

Recent SEC Corp/Fin Interpretations of Interest

Troutman Pepper Locke on 3/31/2025

In new Compliance and Disclosure Interpretations (see CDIs 256.35 and 256.36) and a related no-action letter (Latham & Watkins LLP, March 12, 2025), the staff of the Securities and Exchange Commission’s Division of...more

SEC Offers Updated Guidance for Rule 506(c) Private Placements

Flaster Greenberg PC on 3/27/2025

On March 12, 2025, the SEC published a No-Action Letter clarifying accredited investor verification requirements under Rule 506(c)....more

Less Red Tape, More Capital? SEC Clarifies 506(c) Verification Rules

DarrowEverett LLP on 3/17/2025

On March 12, 2025, the Securities and Exchange Commission (“SEC”) issued a significant no-action letter clarifying the use of high minimum investment amounts as a method for verifying accredited investor status under Rule...more

Back to the Future: SEC Staff Issues Sweeping New Guidance on Shareholder Proposals Mid-Season

Morrison & Foerster LLP on 2/14/2025

On February 12, 2025, the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) published Staff Legal Bulletin No. 14M (SLB 14M), rescinding Staff Legal Bulletin No. 14L (Nov. 3, 2021)...more

SEC Proposes to Modernize the Advertising and Cash Solicitation Rules for Investment Advisers

Herbert Smith Freehills Kramer on 11/7/2019

The Securities and Exchange Commission (the SEC) announced on Monday that it had voted to propose amendments to modernize Rule 206(4)-1 (which addresses investment adviser advertisements) (the Advertising Rule) and Rule...more