Capital Markets & Securities Law Watch

On March 12, 2025, the Securities and Exchange Commission’s Division of Corporation Finance issued a no-action letter clarifying “reasonable steps” issuers can take to verify the accredited investor status of purchasers, as required under Rule 506(c) of Regulation D, a safe harbor promulgated under the U.S. Securities Act of 1933, as amended.

On March 4, 2020, the SEC issued a proposing release (the Proposing Release) to amend the exempt offering framework to address complexities that may impede access to capital for issuers and access to investment opportunities for investors. Under the current framework, there are 10 exemptions (safe harbors) with different requirements.