The American Bar Association’s Committee on State Regulation of Securities publishes The Blue Sky Bugle, a newsletter for blue sky lawyers. In a column for the December issue, Alan Parness, of Cadwalader, Wickersham & Taft LLP, wrote about the enforcement report issued last October by the North American Securities Administrators Association (aka NASAA).

Alan notes that NASAA reported that the states brought more than 250 enforcement actions involving Rule 506 and Regulation D in 2010. Because NASAA didn’t disclose the specific allegations in these actions, Alan did a little digging. He found that Arkansas had brought 12 orders specifically involving Rule 506 and that each of these orders alleged failure to file a Form D in a timely fashion. The orders did not allege fraudulent practices or that the issuer had otherwise failed to comply with Rule 506.