Tuesday, December 10, 2013
When the SEC adopted the Rule 506(c) amendment allowing general solicitation in certain Regulation D offerings, it also proposed a number of changes to Regulation D. The Federal Regulation of Securities Committee of the American Bar Association' s Business Law Section, recently submitted a very thoughtful comment letter on those proposed changes. It's available here.
I have been a member of the Federal Regulation of Securities Committee and several of its subcommittees for over two decades. Almost all of the country's top securities lawyers are members. (I'm not sure why they let me join.) I don't always agree with the committee's views, but its positions are always thoughtful and well-reasoned. This letter is no exception (and, in this case, I happen to agree with most of it). It's worth reading.