May 23, 2016

Crowdfunding Starts With a Bang! (Or a Whimper?)

As could be expected, a number of players were chomping at the bit last Monday when Regulation Crowdfunding became effective. The lowdown of this activity is covered in this blog by Steve Quinlivan – including the 29 issuers who filed a Form C with the SEC (which is the requisite filing to commence crowdfunding) so far. As noted in this blog by Gunster’s Robert White, crowdfunding would even be much more popular if the framework were different – but there are efforts afoot to get the problems fixed…

Crowdfunding: NASAA’s Proposed Model Rule

As noted in this MoFo blog and this blog, the North American Securities Administrators Association (NASAA) has proposed a model rule & uniform notice filing form (Form U-CF) for crowdfunded offerings…

Conflict Minerals: Analysis of Early Filings

As folks wrap up their conflict minerals reports ahead of next Tuesday’s deadline, it might be useful look over this Elm Sustainability Partners analysis of the reports filed early this year, including:

– Most of the CMRs so far contain language that would make for an expensive IPSA similar to what was warned about last month.
– Several CMRs do not include a list of smelters/refiners.
– Although we support brevity in CMR language, that has limits. One CMR is a total of 15 sentences with no listing of smelters/refiners or countries of origin.

Broc Romanek