What’s Investment Advice?

As the clock ticks down to Dec. 31, it is becoming more clear that the SEC’s crowd funding rules are going to have to be a work in progress, regardless of how detailed they turn out to be. Crowd funding is a blank slate concept where new twists surface every day. Witness the claim that providing a product sample may be considered to be “investment advice” in a recent Washington Post article about the Reg. D crowd funding website Circle Up. Is it? What if C-Up just told the investor what store to buy the product in? Less of investment advice?

http://www.washingtonpost.com/business/on-small-business/crowdfunding-platform-ships-product-samples-to-potential-investors/2012/11/29/b0c64e5c-3a74-11e2-a263-f0ebffed2f15_singlePage.html?tid=obinsite

About JeffKoeppel

I am a corporate/securities attorney in the Washington, DC area. Prior to joining the firm, I was a Senior Attorney Advisor in the Division of Corporation Finance at the U.S. Securities and Exchange Commission. I am a member of the Bars of the States of Maryland, New York and the District of Columbia. You can also follow this blog on LinkedIn at: http://www.linkedin.com/pub/jeffrey-a-koeppel/0/63/5a9
This entry was posted in Broker dealers, Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, FINRA, Funding Portals, Investments, Legislative Intent, SEC, Wall Street and tagged , , , , , , , , , , , , , , , , , , , . Bookmark the permalink.

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