Rick Colosimo

I recently came across a situation where we used “net revenue” in a bonus plan as part of the calculation to determine what the bonus pool would be. In other contracts, we’ve used “net revenue” to distinguish from “revenue” (aka gross revenue) to deduct things like discounts, credits, returns, and so on. In many of…

The 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…

As part of the crowdfunding regulations, the SEC created heightened standards for determining whether an investor was accredited, requiring issuers (that means the startup company) to take “reasonable steps” to determine whether each investor who is part of a general solicitation offering under 506(c) is in fact accredited. Here’s a short overview of these rules,…

A friend recently asked me about Startup-NY, New York’s new program ostensibly designed to help foster startups. As you might expect, the bark is better than the bite. Fundamentally, there are a bunch of complicated rules, exceptions, and requirements, and some conveniently unstated limits. Now, since I think the prerequisites will gut most of the…