Tag Archives: issuer

Funding Portal’s Diligence Questioned

Under new Regulation Crowdfunding, a funding portal is required to deny access to its website if it has a “reasonable basis for believing that the issuer or the offering present the potential for fraud.” (A fairly subjective standard that will, … Continue reading

Posted in accredited investor, Broker dealers, Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, discrepancies, fine, fraud, Funding Portals, Investments, Jobs, Legislative Intent, review, SEC, Small Business, States, technology, VC, Venture Capital, Wall Street | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

The Cop Is On the Beat

The SEC’s Enforcement Division released its stats for its 2014 fiscal year, noting its use of “data and analytical tools.” Highlighting their “successful” year, the Division “filed a record 755 enforcement actions covering a wide range of misconduct, and obtained … Continue reading

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, Jobs, Legislative Intent, SEC, Wall Street | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

SEC Permits Fall Back Verification Methods

The SEC has indicated that even if you cannot use one of the safe harbors under Rule 506(c) to verify that an investor is “accredited,” other evidence could be relied upon to do so under the “principles based” verification method. … Continue reading

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, Jobs, SEC, Small Business, Venture Capital | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Crowdfunding Trust and Safety

Crowdfunding fraud can work in various ways. Kickstarter now has a “Trust and Safety Team” that reviews campaigns and responds to fraud complaints from donors. Many of the complaints focus on the failure to deliver rewards when promised. Delivery failure … Continue reading

Posted in Broker dealers, Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, Funding Portals, Investments, Jobs, Legislative Intent, SEC, States | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Crowd Funding Regs Hold Some Surprises

Upon review of the SEC’s proposed crowd funding regulations released this week, I found a number if items that could be problematic for companies that thought they would have a relatively easy time raising funds using the new Section 4(a)(6) … Continue reading

Posted in Banking, Broker dealers, Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, Film, FINRA, Funding Portals, Investments, Jobs, Legislative Intent, SEC, Small Business, Venture Capital, Wall Street | Tagged , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

You Believe Me, Don’t You?

The regulatory trade-off made by the SEC in permitting issuers to advertise a private placement was to have them take reasonable steps to verify that the purchasers are, in fact, “accredited investors.” In today’s Wall Street Journal, an op-ed writer … Continue reading

Posted in 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, Small Business, Wall Street | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment