kaal:claim:2714974-021

Until the SEC finalizes verification rules and gives a clear, comprehensive definition of the reasonable steps an issuer must take, issuers cannot determine at the time of sale whether their verification attempts made general solicitation permissible.

Source quote, verbatim

Without appropriate SEC guidance, issuers will have difficulty ascertaining if their verification attempts at the time of the sale of securities made GSGA permissible.

From

Kaal and Oesterle, The History of Hedge Fund Regulation in the United States (2016), Hedge Funds Can Advertise Generally, p. 19
https://ssrn.com/abstract=2714974 · source PDF

Cite as

Kaal and Oesterle, The History of Hedge Fund Regulation in the United States (2016). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2714974

Holds when

conditional on the absence of finalized SEC verification guidance

Classification

conditionsupport: arguedfailure: Indeterminate reasonable steps standardfamily: definitional-ambiguitysecurities-law

Verify

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Attestation record: colloquium/attestations/400ff60f765440c4...json
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