JOBS Act Implementation

On October 30, 2013, the Director of the SEC's Division of Corporation Finance, Keith Higgins, testified at the Senate hearings on JOBS Act implementation (see our prior blog post on this).  His testimony can be found here:  http://www.banking.senate.gov/public/index.cfm?FuseAction=Files.View&FileStore_id=49b38b62-cdff-4e2d-b272-26c5e44d785f.

In his testimony, Mr. Higgins provided a number of updates.  He noted that the SEC Staff is working with national securities exchanges as they develop a plan to implement a pilot program permitting smaller companies to implement wider tick sizes.  Higgins also reported that the SEC Staff expects to deliver its report on disclosure requirements under Regulation S-K.  In comments relating to Title II, the testimony (footnote 18) cites statistics for offerings made in reliance on Rule 506(c) using general solicitation.  Based on Form D filings, the SEC states that 170 offerings have been made using general solicitation, and 44