Reg D Rule 506 Private Offerings: Verifying Accredited Investors and Identifying "Bad Actors"

Since Rule 506 was changed in 2013, we have seen new practices in securities offerings to comply with:

• The issuer's obligation to use reasonable steps to verify that all investors in Rule 506 (c) offerings are accredited investors. How is the inability of investors in Rule 506 (c) offerings to self-certify their accredited investor status affecting capital raising?
• Rule 506 (d)'s requirement for all Rule 506 offerings that issuers make factual inquiries into whether people associated with the issuer or with deal intermediaries have committed a list of "bad acts."

Listen as our authoritative panel of securities practitioners analyzes SEC rules and counsel due diligence in Reg D Rule 506 private offerings for verifying that investors meet the definition of “accredited investors” and that they are not precluded from participating in the offering by the “bad actors” provisions.