Tag Archives: reasonable care

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 … 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, Legislative Intent, SEC, Wall Street | 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

SEC Offers Bad Actor Clarity

In an attempt to clarify new Rule 506(d) that would disqualify an issuer’s exemption under Rule 506 if “covered persons” have engaged in “disqualifying acts,” the SEC issued a new set of interpretations, that include: determining a bad actor at … 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, Legislative Intent, SEC, Small Business, Venture Capital, Wall Street | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment