In general, from the board perspective, my preference is to let the CEO and outside counsel sort out any SEC compliance issues. There are two kinds of problems that pop up over and over again: first, questions about whether the company can pay a finder’s fee in connection with introductions; and second, what the company…
Read MoreI’ve been meaning to write a post about accredited investors for some time now, and a random Quora question just got most of my fury. Here’s the steak: Actually, the Securities Act of 1933 (LII link)) regulated public offerings. The definition of accredited investor appears in Rule 501 of Reg D (LII link), which is…
Read MoreThe redacted email below was sent to the Cornell NYC/ tri-state community – thousands of people. Conveniently, it’s not automatically a securities law violation any more, but this is definitely how to be sure you’ve fallen under the new general solicitation rules, which require a company to take “reasonable steps” to verify that each investor…
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