Financial Industry Developments

SEC Publishes Compliance and Disclosure Guidance for Regulation Crowdfunding

On April 5, 2017, the Division of Corporation Finance of the Securities and Exchange Commission ("SEC") published a "Compliance and Disclosure Interpretation: Regulation Crowdfunding: Rule 202: Ongoing Reporting Requirements." The issues addressed are (i) how an issuer should calculate the number of holders of record for purposes of determining eligibility to terminate its duty to file certain ongoing reports; (ii) may an issuer advertise the "terms of the offering" under Regulation Crowdfunding; (iii) whether an issuer may advertise the "terms of the offering" through a video; (iv) whether the limitation on advertisements applies only when the advertisement includes any of the "terms of the offering"; and (v) whether a third-party publication, such as a media article, could constitute a notice that would be subject to the limitations on advertising. Rule.

Rating Agency Developments

On April 6, 2017, Fitch issued a report entitled Fitch: Early Signs are Positive for Risk Retention in U.S. CMBS. Release.