In an effort to clarify its interpretation of Securities Act Rules 144A and 506(c), the SEC’s Division of Corporate Finance released 11 new compliance and disclosure interpretations (CD&Is) on November 13, 2013. The new CD&Is clarified, among other things, that the amendments to Rule 144A permitting the use of general solicitation did not change how directed selling efforts under Regulation S are analyzed in side-by-side Rule 144A and Regulation S offerings. For the complete set of C&DIs for the Securities Act Rules, click here. The 11 new CD&Is are questions 138.03, 138.04 and 260.05 through 260.13.