Reasonable Steps to Verify Accredited Investor Status. Rule 506(c) as adopted contains both a general requirement that issuers take “reasonable steps” to verify that purchasers are accredited investors, as well as a non-exclusive list of methods that can be used to satisfy this requirement. As originally proposed, Rule 506(c) did not mandate a particular verification process…

In 2012 Congress passed the JOBS Act, which mandated the creation of a new offering exemption under the Regulation D 506 program that would allow for general advertising of an offering to accredited investors.  The rules went into effect on September 23, 2013.  Prior to the passage of the JOBS Act (and the subsequent promulgation…

Title III of the Jumpstart Our Business Startups (JOBS) Act of 2012 provides for securities based crowdfunding with the intention of making it easier for small businesses and startups to raise funds and for individuals to become investors.  The Securities and Exchange Commission (SEC) released its proposed rules governing crowdfunding, “Regulation Crowdfunding,” in  October of…