News & Analysis as of

Private Placements Investment Funds

Alston & Bird

FINRA Delays Implementation Date for Previously Adopted Changes to Filing Fees for Public Offering and Private Placement Reviews

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New fees from the Financial Industry Regulatory Authority (FINRA) are now on hold until 2027. Our Investment Funds Team examines the new schedule for public offering and private placement reviews....more

Proskauer Rose LLP

SEC Eases Verification Burdens in Rule 506(c) Offerings

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The SEC’s Division of Corporation Finance recently issued an interpretive letter providing additional insight as to what constitutes “reasonable steps” to verify an investor’s accredited investor status under Rule 506(c) of...more

Foley & Lardner LLP

No Action Letter – Regulation D Rule 506(c)

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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

Tannenbaum Helpern Syracuse & Hirschtritt LLP

SEC Resolves Uncertainty around Verification Requirement for Private Offerings under Rule 506(c)

On March 12, 2025, the Division of Corporation Finance (the “Division”) of the SEC issued a no-action letter (the “No-Action Letter”) providing new guidance on Rule 506(c) of Regulation D under the Securities Act....more

Latham & Watkins LLP

FAQs on the Latham Letter for Exempt Offerings with General Solicitation Under Rule 506(c)

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On March 12, 2025, Latham obtained SEC Staff guidance on the use of general solicitation in private placements. The guidance unlocks the full potential of Regulation D Rule 506(c) by clarifying that issuers may satisfy the...more

Goodwin

FINRA Proposes to Add ‘Knowledgeable Employees’ to Category of Persons Who May Receive Projections and Targeted Returns Under Rule...

Goodwin on

This amendment builds on FINRA’s recent willingness to relax the prohibition on the use of projections and targeted returns in the marketing materials broker-dealers deliver to institutional investors and qualified...more

Conyers

ケイマン諸島でヘッジファンドを設立する

Conyers on

ケイマン諸島は、オフショアヘッジファンドの設立において世界をリードしています。税制中立のプラットフォーム、安定した経済、洗練された銀行部門、機密保持、専門的な金融サービス産業は、この地が世界中のヘッジファンド・マネージャーにとって魅力的である理由の一部となっています。...more

Dorsey & Whitney LLP

Raising U.S. Funds Under Canada’s New “Listed Issuer Financing Exemption”

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​​​​​​​As many of our readers will have heard, the Canadian Securities Administrators (“CSA”) has announced the adoption of a new prospectus exemption for certain reporting issuers listed on a Canadian stock exchange (the...more

Allen Matkins

Forming Your First Real Estate Fund

Allen Matkins on

The COVID-19 pandemic has resulted in seismic shifts to the real estate industry over the last year. Shifting preferences and governmental restrictions severely impacted retail, hospitality and commodity office asset classes....more

Morrison & Foerster LLP

FINRA Provides Guidance On Retail Communications In Private Placements

In July 2020, FINRA issued Regulatory Notice 20-21, which is designed to provide guidance to broker-dealers in connection with their creation and use of retail communications relating to private placements. The notice...more

BCLP

Spring Budget 2020: overview from a funds perspective

BCLP on

This briefing summarises the key announcements in the Spring Budget from a funds perspective: including the UK funds review, the SDLT surcharge for corporate and individual non-resident purchasers of UK residential property...more

Eversheds Sutherland (US) LLP

In tune with the SEC - staff continues dialogue on harmonizing private exemptions

On June 18, 2019, the Securities and Exchange Commission (the “SEC”) issued a concept release (the “Release”) on ways to “simplify, harmonize, and improve the exempt offering framework to expand investment opportunities while...more

White & Case LLP

Schuldscheine – a global alternative product of the future?

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Schuldscheine, no longer exclusively German products, are gaining international popularity as issuers and financial institutions realise their efficiency, flexibility and propensity for innovation. In the face of uncertainty...more

Latham & Watkins LLP

European Commission Report on the Operation of the AIFMD

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Report concludes that the AIFMD has been helpful in building a market for AIFs, but is not free from issues. Key Points: ..The report concludes that the AIFMD has played a significant role in helping to create an...more

Gerald Nowotny - Law Office of Gerald R....

It Do Me Good!

Structuring Inbound Investment by Foreign Investors Using Private Placement Insurance Products - Overview - By now most of you that have followed my articles know that I grew up in the Panama Canal Zone and studied...more

Morgan Lewis

Regime for Marketing Foreign Funds in the UAE

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Exploring the rules governing marketing in the UAE of interests in foreign (non-UAE) funds, and in particular the various exemptions from the general requirement that such foreign funds be registered with the Securities and...more

King & Spalding

MEasure - Winter 2017

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Amendments to Foreign Fund Private Placement Exemptions in the UAE - In August 2016, the Emirates Securities and Commodities Authority (SCA), the federal securities regulator of the United Arab Emirates (UAE), adopted...more

King & Spalding

Loss of Foreign Fund Private Placement Exemptions in the UAE

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In August 2016, the Emirates Securities and Commodities Authority (SCA), the federal securities regulator of the United Arab Emirates (UAE), adopted new investment funds regulations (the 2016 Fund Regulations), which repealed...more

Bennett Jones LLP

Harmonized Reporting for Private Placements (with Increased Disclosure Requirements)

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An issuer that distributes securities to the public must either file a prospectus with securities regulatory authorities and deliver such prospectus to prospective purchasers, or rely upon a prospectus exemption available...more

Blake, Cassels & Graydon LLP

One Size for All: Increased Private Placement Reporting Begins June 30

Effective June 30, 2016, issuers will have to report prospectus-exempt distributions that settle on or after that date in any Canadian jurisdiction using a new, harmonized Form 45-106F1 (New Form), with significantly...more

Goulston & Storrs PC

What's Market? Update: Securities

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Amendments to Regulation A adopted by the SEC to comply with a mandate in the JOBS Act took effect on June 19, 2015. Regulation A as amended (often referred to as “Regulation A+”) expands the maximum aggregate amount that...more

Carlton Fields

SEC Charges EB-5 Brokers For Not Registering

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Multiple firms involved in the solicitation of investment capital for the Immigrant Investor Program (also known as "EB-5") have recently been charged by the SEC with acting as unregistered brokers. Neither In re Ireeco, LLC,...more

Blake, Cassels & Graydon LLP

Yet More Enhancements Proposed for Private Placement Reporting

The Canadian Securities Administrators (CSA) have managed to harmonize their differences for reporting prospectus-exempt distributions since their earlier proposals in February and March 2014. They have now proposed a common...more

Akin Gump Strauss Hauer & Feld LLP

Extension of the AIFMD Passports to Non-EU Alternative Fund Managers and Non-EU Alternative Investment Funds

Hardwired into the European Union (EU) Alternative Investment Fund Managers Directive (AIFMD) is a mechanism that could enable a non-EU alternative fund manager domiciled outside the EU to become authorised by an EU regulator...more

Seyfarth Shaw LLP

SEC Charges EB-5 Fund Operators and Finders

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The Securities and Exchange Commission (the “Commission” or “SEC”) has become increasingly active in enforcing alleged violations of U.S. securities laws arising under the EB-5 Immigrant Investor visa program. EB-5...more

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