David Jenson

David Jenson

Stinson Leonard Street

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New C&DIs on Verification of Accredited Investor Status

On July 3, 2014, the SEC released six new Compliance and Disclosure Interpretations relating to verification of prospective investors as accredited investors for purposes of Rule 506(b) and Rule 506(c). Two of these C&DIs...more

7/7/2014 - "Rule 506(b) Accredited Investors C&DIs IRS Rule 506(c) SEC

Verifying Accredited Investors in Public Rule 506 Offerings: SIFMA Guidance

On June 23, 2014, the Securities Industry and Financial Markets Association (SIFMA) published a memo outlining several specific methods for verifying accredited investor status that SIFMA believes would satisfy the...more

6/30/2014 - Accredited Investors Broker-Dealer General Solicitation Investment Adviser Private Offerings Rule 506 Offerings Rule 506(c) SIFMA Startups

SEC Chair Discusses Potential Changes To Accredited Investor Definition

In a November 15, 2013 letter to Representative Scott Garrett (Chairman of the Subcommittee on Capital Markets and Government-Sponsored Enterprises for the House Financial Services Committee), SEC Chair Mary Jo White...more

11/19/2013 - Accredited Investors Dodd-Frank Mary Jo White SEC

10 Minute Overview Of General Solicitation And Crowdfunding

On August 19, Nicole Strydom and I gave a 10 minute presentation on the general solicitation rules and the current status of “crowdfunding” at a ceremony to announce the finalists in the student division of the Minnesota Cup....more

8/23/2013 - Accredited Investors Crowdfunding General Solicitation JOBS Act Regulation D Rule 506 Offerings SEC

Proposed Minnesota Investment Adviser Legislation

There is a bill working its way through the Minnesota state legislature that amends chapter 80A of the Minnesota Statutes to, among other things, implement investment adviser registration for investment advisers whose only...more

3/18/2013 - Accredited Investors Investment Adviser Private Funds Proposed Legislation Registration

New FAQs On Broker-Dealer Registration Exemption

On February 5, 2013, the SEC released FAQs regarding Section 201 of the JOBS Act, which offers a new limited exemption from broker-dealer registration....more

2/8/2013 - Accredited Investors Broker-Dealer Exemptions JOBS Act Registration Rule 506 Offerings SEC Securities

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