SEC Proposals Regarding Private Offerings

The SEC's proposed changes to private offerings, including proposed changes to Form D, Form D filing requirements, and temporary requirements to submit general solicitation materials, already are generating comment.  Reps. McHenry and Garrett have requested that, among other things, the SEC clarify that issuers will be able to rely on new Rule 506(c) following the September effective date without having to comply with the additional proposals in the future.  Their letter requests answers to a number of other questions.  The letter may be accessed here:  http://mchenry.house.gov/uploadedfiles/mchenry_garrett_to_sec_chair_white_07.22.2013.pdf.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.