Under A Clear Blue Sky?

On April 8, Commissioner Aguilar and Commissioner Stein spoke at the North American Securities Administrators Association conference.

Commissioner Aguilar noted in his remarks that "Regulation A-plus remains a work in progress, and no one can say what the ultimate outcome will be."  The Commissioner went on to note that a workable exemption would "attract issuers that might otherwise choose more opaque exemptions for their capital-raising needs."  Indeed, in Rule 506 offerings to accredited investors, there are no disclosure requirements, no investment limit, and no ongoing reporting obligations.  The proposed Reg A+ framework provides enhanced investor protections that should mitigate any concerns; however, the debate regarding pre-emption continues.