Timeline--The JOBS Act; When Does It Really Go Into Effect? By: Kaiser Wahab and Lauren Mack

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Given the excitement, anxiety, and confusion over when the various provisions of the recently signed JOBS Act will come into effect, we have put together a helpful timeline that shows when the SEC’s rulemaking must be completed and the maximum duration of the studies the SEC is obligated to perform. It is important to note that while some provisions related to the new crowdfunding exemption will be in effect 90 days from enactment, such as the revisions to Rules 506 and 144A, the actual crowdfunding provisions themselves do not need to be completed by SEC until 270 days after enactment, making them due at the end of 2012. Additional provisions included in the JOBS Act that do not have deadlines require the SEC to revise the definition of “held of record,” provide safe harbor provisions that issuers can use to determine whether holders of their securities received the securities through a compensation plan, and revise Regulation A’s offering threshold to $50 million in any 12-month period.

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