NASAA’s Perceived Threats

In its annual list of risks posed to investors and small businesses, NASAA once again identifies private offerings.  NASAA notes that "[f]raudulent private placement offerings continue to rank as the most common product or scheme leading to investigations and enforcement actions by state securities regulators."  NASAA notes that the relaxation of the ban on general solicitation for certain Rule 506 offerings may increase the possibility for fraudulent practices.  In its new threats to smaller businesses, NASAA cites crowdfunding-type platforms, which may create new areas of risk for start-ups and entrepreneurs who may not be familiar with securities law requirements associated with capital raising.  Along the same lines, NASAA identifies "unregulated third party service providers," such as portals or crowdfunding platforms that may not be regulated entities as well as unregulated entities providing investor verification services.  NASAA cautions that users