# kaal:claim:2714974-022

**Claim.** Neither obvious remedy for the increased sales pressure created by the Rule 506 amendment works well: added disclosure obligations such as filing all Rule 506 sales documents with FINRA or the SEC may burden issuers inappropriately, while litigation based enforcement may not reach all offenders equally or appropriately.

**Type.** failure  **Support.** argued

**Holds when.**

- applies to private placements where commissions exceed those on other investments

**Source quote.**

> Litigation-based enforcement, on the other hand, may not encapsulate all offenders equally and/or appropriately.

**From.** Kaal and Oesterle, *The History of Hedge Fund Regulation in the United States* (2016), Hedge Funds Can Advertise Generally, page 19

**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

**Verify.** sha256 of source PDF `7764601d3ed5bb056b58949e8411eff9dfb9855f143719062030c980c5fa801b` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20and%20Oesterle%20-%202016%20-%20The%20History%20of%20Hedge%20Fund%20Regulation%20in%20the%20United%20States.pdf

**Failure mode.** Both remedies for sales pressure underperform  (family: investor-protection-gap)

**Topics.** compliance, disclosure

**Keywords.** sales-pressure, finra, enforcement, private-placements, disclosure

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