Preparing for an A+ grade: the SEC gets to see all your stuff!
There’s an increasing amount of publicity out there from companies that are “testing the water” (TTW) before deciding to make a Regulation A offering. At CrowdCheck, we love the idea of TTW. It’s an efficient way of making sure that it’s going to be worth a company’s time to hire lawyers and accountants and go […]
Preparing for an A+ grade: the need for a clean audit
Pretty much everyone knows by now that audited financial statements are required for offerings under Tier 2 of Regulation A. While the SEC doesn’t require audited financials (or any kind of review by outside accountants) for Tier 1, some states do require audited financials in Tier 1 offerings. But do you know what the audit […]
The case of the vanishing Form 1-A filings
Those of us keeping an eye on filings under revised Regulation A (“Regulation A+”) have noted that, as of today’s date, there have been six public filings and five of those have apparently been withdrawn. [Correction: they weren’t withdrawn, they were required to be amended prior to review.] I don’t think the chances of the […]
SEC provides guidance on Regulation A questions
The Staff of the SEC’s Division of Corporation Finance has posted some Compliance and Disclosure Interpretations (“CD&Is”) here (scroll down to Section 182). Nothing surprising, but some useful stuff there. Possibly the most important interp is the one relating to Twitter (Q 182.09), which says if you can’t fit the disclosure required by Rule 255 into a […]
Regulation A: what just happened?
Good lord, there is a lot of nonsense being written about revised Regulation A, which went into effect this morning. People are saying the SEC has opened up investment to a whole new class of investors and companies. People are saying that companies were never able to publicly solicit from non-accredited investors before. People are […]
Preparing for an A+ grade: are you sure you want to do this?
Less than a week to go before the revisions to Regulation A go into effect and many companies are making plans to make an offering. It’s not too late to back out, though! It may seem odd that I’m saying this as both I personally and CrowdCheck as a company are very much in favor […]
Preparing for an A+ grade: SEC comments on financials
By this point everyone knows that the financial statements you must provide to the SEC in Tier 2 Regulation A offerings must be audited by a CPA. We are seeing reputable CPAs offer their services at very reasonable prices for early-stage companies. But companies need to know exactly what is covered in their agreement with […]
Preparing for an A+ grade: drafting dull documents
Just over two weeks to go to revised Regulation A going into effect (setting aside the litigation) and time for another blog post. This time I’m looking at what an Offering Circular (the prospectus-like document that makes the offer of securities) is going to look like. You’re going to be disappointed. It’s going to be […]
Preparing for an A+ grade: testing the waters
Three weeks to go to effectiveness of new Regulation A (we’ll ignore the litigation for the moment), and time for a new topic: “testing the waters” (TTW). One of the great things about Reg A is the ability to find out, at low cost, whether it’s worth hiring lawyers and accountants to prepare the filing with the […]
Massachusetts gives A+ an F
…for “filing a federal lawsuit” that is. On the Friday before the long weekend, William Galvin of Massachusetts filed in the US Appeals Court for the District of Columbia asking for an injunction against Reg A+ going into effect on June 19. Watch this space for developments. Update [1 pm Tuesday] . . . Montana is also […]