On March 12, 2025, the SEC’s Division of Corporation Finance issued guidance affirming that issuers in a 506(c) offering could reasonably be considered to have properly "verified" an investor's accredited status based simply...more
Securities issuers and their counsel have historically relied on the fact that the SEC has not pursued enforcement actions against issuers that have not filed, or been delayed in filing, a Form D in connection with offerings...more