- The recent
CD&Is on Rule 147 tell us that companies can use third-party internet
portals to conduct intrastate crowdfunding offerings, but that it’s going to be
really tough for them to “go it alone” and use their own existing internet or
social media presence to promote offerings.
- The proposed
Securities Act Section 4(a)(6) “crowdfunding” rules under Title III of the JOBS
Act require companies to use registered funding portals to conduct
- Procedures under new Rule 506(c) favor the use of third parties (registered broker-dealers, CPAs, attorneys, etc.) for verification of accredited investor status.
Benji Jones is a Partner at Smith Anderson, focusing on corporate and securities work (particularly private offerings). She also teaches at Campbell Law and lives with her family here in Raleigh.