SEC Issues Guidance Regarding New General Solicitation Rules

On November 13, 2013, the Division of Corporation Finance of the Securities and Exchange Commission (the "SEC") issued new Compliance and Disclosure Interpretations ("CDIs") providing guidance regarding new rules allowing for general solicitation in private offerings. The new guidance will be of interest to any private fund sponsor engaged in or contemplating engaging in general solicitation in connection with a private fund offering under new Rule 506(c) under Regulation D, and to sponsors wishing to transition between a traditional Rule 506(b) offering and a general solicitation offering under Rule 506(c), or from a Rule 506(c) offering to an offering under Securities Act Section 4(a)(2).