The new public solicitation provisions of Rule 506(c) and bad actor disqualifications under Rule 506(d) have been effective for a month now. Issuers, distribution participants, funding sources and third party service providers are all faced with the challenge of developing appropriate policies and procedures that will satisfy the reasonable steps and reasonable care standards under the new rules, provide adequate disclosure of prior disqualification events under the transition rules and safeguard confidential investor information. Navigating this new space is not easy, but can be done effectively.
During this webinar, our attorneys will share their unique insights based on client experiences, their own analysis and conversations with counsel from several broker-dealers. Specifically, we will discuss:
- Events that may trigger disclosure or disqualification of bad actors
- Emerging best practices for exercising reasonable care in identifying bad actors
- Common challenges in verifying accredited investor status
- The role of third party service providers
- Other frequently encountered questions
This webinar is intended for sponsors, issuers and broker-dealers that are conducting or participating in Rule 506 offerings as well as third party service providers of verification services or funding portals.