TheCorporateCounsel.net

Last week, NASAA – the organization for state securities regulators – proposed a coordinated review program for Section 3(b)(2) offerings (known as “Reg A+”) in an effort to maximize efficiency and coordination among the states. The comment period runs until November 30th. As noted in this press release, a streamlined multi-state review system would ease compliance costs for small companies attempting to raise capital under Title IV of the JOBS Act.

As noted in this MoFo blog, Corp Fin is in the process of finalizing A+ offering rule recommendations under Title IV for the Commission’s consideration.

Enforcing Form D Filings: A Misguided State Policy

Here’s an interesting blog from Keith Bishop about some insights by Alan Parness about the relatively high number of enforcement actions taken by states for a failure to file a Form D. “Relatively” given the fact that a failure to file the Form doesn’t result in the loss of the ability to use Rule 506. Note this blog was written quite a while ago, well before the SEC’s new changes to the rules…

Now Available: Electronic SEC Confidential Treatment Orders

Here is one that I’ve been meaning to blog about for years (I have all sorts of draft blogs that never see the light of day) – not pressing because it’s not of much significance – Corp Fin’s confidential treatment orders are now available electronically on Edgar. For example, here is an order issued in connection with a CT request made by Antigenics.

– Broc Romanek