Freitag, 8. November 2013

The Jobs Act Title III: Comments On Comments

The SEC recently released its proposed rules for Title III of the JOBS Act (i.e. “crowdfunding”) which, while a major step in the opening of this market, does not mean that issuers are now able to pursue crowdfunding transactions. The rules that were proposed by the SEC will be subject to a comment period and the release and adoption of final rules.

As a result, we continue to receive a lot of questions on the JOBS Act: what can and can’t be done with respect to marketing securities transactions now (general solicitation?), the types of investors that can invest (accredited investors only?), the types of transactions issuers can pursue (Title II vs. Title III?), the timing of any upcoming changes, whether new investor networks can be started now by Joe Public and pretty much everything else.

We will release a summary of the rules as proposed by the SEC and the registration process proposed by FINRA in short order.  However, as the proposed rules generally follow the requirements of the JOBS Act, the discussion below provides a good snapshot of where things stand at the moment.

I have run through some of the most frequently asked questions that we receive, attempted to put things into language that makes sense, given an idea of where things currently stand and maybe shed some light on where things (might) go in the near future.

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