SEC's Dating Advice For Internet Platforms And Its Impact

Law360, New York (August 19, 2015, 11:22 AM EDT) -- Jeffrey A. Clopeck

Eliza Sporn Fromberg Can you form a substantive, pre-existing relationship in fewer than 30 days? For Internet platforms offering private placements in reliance on Rule 506(b) of Regulation D, the answer is "yes." Based on a U.S. Securities and Exchange Commission no-action letter issued to Citizen VC Inc. on Aug. 6, 2015, and a series of compliance and disclosure interpretations (C&DIs) issued on the same date by the SEC Division of Corporation Finance, an Internet platform may engage in "speed-dating" with prospective investors it meets online so long as the platform asks probing questions. In essence, the SEC...

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