The SEC’s Division of Corporation Finance recently issued an interpretive letter[1] providing additional insight as to what constitutes “reasonable steps” to verify an investor’s accredited investor status under Rule 506(c) of Regulation D, a private offering exemption that permits general solicitation. Compared to Rule 506(b), which does not permit general solicitation, Rule 506(c) is

Bradley Schecter
Brad Schecter is an associate in the Corporate Department and a member of the Private Funds Group.
Brad has a general corporate practice, with an emphasis on representing U.S. and non-U.S. private investment fund sponsors in connection with a broad range of issues, including fund structuring and formation, investments, regulatory issues and compliance, internal governance, and day-to-day management and operations.
Prior to joining Proskauer, Brad practiced at Davis Polk & Wardwell LLP in New York, where he represented a range of financial institutions, institutional investors and companies in connection with distressed investment opportunities, corporate restructurings, bankruptcy proceedings, and regulatory issues.
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