“One and done” SPV reporting? No, not really
A few months ago, I posted about the received wisdom in the crowdfunding industry thatholds that because an issuer used a special purpose vehicle to handle its offering underRegulation CF, that SPV counted as only one “holder of record” for ongoing reportingpurposes. Therefore, the theory goes, issuers could take advantage of the provision inRule 202(b)(2) […]
“Securities Are Sold, Not Bought—But Reg CF Marketing Has Rules: The SEC’s New Reg CF C&DI Guidance”
Advertising and marketing are crucial for Regulation Crowdfunding offerings. As the old sales adage goes – “Securities are sold, not bought.” But marketing an offering compliantly is just as important as the marketing itself, as few activities can get an issuer in regulatory hot water faster than running afoul of the SEC’s rules on promoting […]
“One and done” SPV reporting? Really?
It’s Form C-AR filing season again, and maybe time to discuss an interesting consequence of using a crowdfunding special purpose vehicle (“SPV”). These are used in roughly one quarter of all Regulation CF filings, according to the analysis of our colleagues at Kingscrowd. Everyone in crowdfunding knows that once a company has taken money from […]