News & Analysis as of

Rule 506(c) Private Funds Investment Funds

Robinson Bradshaw

SEC Guidance Increases Opportunity for 506(c) Offerings by Fund Sponsors

Robinson Bradshaw on

On March 12, 2025, the Securities and Exchange Commission (SEC) issued a No-Action Letter (NAL) that clarified and expanded the definition of “reasonable steps” an issuer must take when making an offering under Rule 506(c)....more

DLA Piper

IMpact: Investment Management News - Q2 2025

DLA Piper on

Welcome to IMpact: Investment Management News. In this regular bulletin, DLA Piper lawyers share their insights on key developments that are impacting the investment management industry. Pursuant to rules issued in 2024 and...more

Kohrman Jackson & Krantz LLP

SEC’s New Guidance on General Solicitation Eases Accredited Investor Verification for Private Funds

Last month, the SEC issued a No Action Letter interpreting Rule 506(c) that effectively provides a streamlined path for private fund sponsors to conduct an exempt general solicitation offering pursuant to Regulation D of the...more

Katten Muchin Rosenman LLP

March Brings New Beginnings: SEC Approves Multi-Share Class Exemptive Relief for Private BDCs and Certain Registered Closed-End...

Since March 12, 2025, the US Securities and Exchange Commission (SEC) has approved multiple applications for multi-share class exemptive relief for private business development companies (BDCs) and certain registered...more

Eversheds Sutherland (US) LLP

SEC Staff eases Rule 506(c) verification with high-minimum investment approach

On March 12, 2025, the Securities and Exchange Commission issued a significant No-Action Letter, providing clarity on how issuers can satisfy the “reasonable steps” requirement for verifying accredited investor status in Rule...more

Venable LLP

Private Funds Get a Break: SEC No-Action Letter Offers Relief for Private Fund Verification

Venable LLP on

In a March 12, 2025 no-action letter, the SEC staff provided commonsense guidance relating to verification of accredited investor status under rule 506(c). The guidance aligns with industry practice and has the potential to...more

Hogan Lovells

SEC staff releases guidance relaxing certain aspects of marketing and fundraising

Hogan Lovells on

The Division of Investment Management of the U.S. Securities and Exchange Commission (the SEC) released new guidance on March 19, 2025 that replaces and relaxes prior guidance for registered investment advisers (RIAs) with...more

Alston & Bird

SEC Streamlines Process for Verifying Accredited Investor Status for Certain 506(c) Offerings Based on Minimum Investment...

Alston & Bird on

Our Investment Funds Team reviews new Securities and Exchange Commission (SEC) guidance that allows certain issuers to simplify the subscription process for 506(c) offerings....more

K&L Gates LLP

Rule 506(c) Unchained? The SEC Loosens Requirements for Advertising in Private Capital Raises

K&L Gates LLP on

On 12 March 2025, the US Securities and Exchange Commission (SEC) staff issued a no-action letter that provides private fund sponsors with a concrete, streamlined approach to relying on Rule 506(c), based on minimum...more

Cooley LLP

SEC Staff Takes Steps to Allow Funds to More Comfortably Fundraise Under Rule 506(c)

Cooley LLP on

On March 12, 2025, staff from the Securities and Exchange Commission (SEC staff) issued new guidance regarding Rule 506(c) of Regulation D under the Securities Act of 1933 (Securities Act). We expect that such guidance will...more

Proskauer Rose LLP

SEC Multi-Class Exemptive Relief for Privately Offered BDCs and Closed-End Funds

Proskauer Rose LLP on

On March 12, 2025, the Securities and Exchange Commission (“SEC”) issued a notice on Ares Core Infrastructure Fund’s (“Ares”) application for multi-class exemptive relief (the “Private Placement Multi-Class Relief”). The...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

Ropes & Gray LLP

SEC Issues No-Action Letter Clarifying Rule 506(c) Accredited Investor Verification

Ropes & Gray LLP on

On March 12, 2025, the Securities and Exchange Commission (the “SEC”) Division of Corporate Finance issued a no-action letter (the “Letter”)1 clarifying “reasonable steps” issuers can take to verify purchasers’ accredited...more

Troutman Pepper Locke

SEC Broadens Guidance on Accredited Investor Verification

Troutman Pepper Locke on

The Securities and Exchange Commission (SEC) has issued a no-action letter providing new interpretive guidance on the verification of accredited investor status in offerings conducted under Rule 506(c) of Regulation D, which...more

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