Bad Actor Interps

The SEC is trickling out some interpretations on the Rule 506(d) “bad actor” disqualification.

A couple of recent ones included:

  •  All persons who have been or will be paid, directly or indirectly,remuneration for the solicitation of investors, including marketing personnel of the general partner, managing member or investment manager of a private fund may be considered a “covered person” and subject to the “bad actor” disqualification under Rule 506(d) based on a recent SEC interpretation.
  • However, convictions, court orders or injunctions issued by non-U.S. regulatory authorities would not trigger the “bad actor” rules.

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:
This entry was posted in Broker dealers, Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, Film, FINRA, Funding Portals, Investments, Legislative Intent, SEC, Wall Street and tagged , , , , , , , , , , , , , , , , , , . Bookmark the permalink.

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