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Tag: Bad actor

What is a “Voting Equity Security” under the Bad Actor Rule?

Doug Cornelius May 28, 2015May 28, 2015 Fundraising   [+]

When the Securities and Exchange Commission adopted Rule 506(d), it did not define “voting equity securities.” That left many fund managers having to take an aggressive approach on compliance with the “bad actor rule.” The SEC has provided some additional clarity. I have to admit that I did not pay much attention to the recent … Read more »

Bad Actors on Form ADV and Under Rule 506(d)

Doug Cornelius June 12, 2014 Compliance Programs   [+]

The Securities and Exchange Commission has layered two tests for bad actors on to private fund managers. On Form ADV, the fund manager will need to disclose bad actor events. Then the second test comes under the new Rule 506(d) that also requires disclosure for bad actors in private placements and a bar for recent … Read more »

The New Rule 506(d) and Bad Actors

Doug Cornelius July 22, 2013July 19, 2013 Corporate Governance, Fundraising   [+]

At its latest meeting, the Securities and Exchange Commission approve the rule that lifted the ban on general solicitation and advertising for certain private placements. The SEC also adopted the new rule that disqualifies felons and other bad actors from participating in certain securities offerings. The first rule was mandated by the JOBS Act. The … Read more »

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