Robyn Stewart 11/22/21 Robyn Stewart 11/22/21

NEW RULE 148 TO EXEMPT “DEMO DAYS” FROM GENERAL SOLICITATION

Effective as of March 15, 2021, the SEC adopted the new Rule 148 which permits entrepreneurs to speak more openly about opportunities for investment in their new enterprises at “Demo Days.” Outlined here are the essential elements of the new Rule 148.

Dan DeWolf 1/6/21 Dan DeWolf 1/6/21

"Gig" Workers May Become Eligible to Receive Equity Compensation

By Dan DeWolf and Sanjana Ramkumar

The Securities and Exchange Commission (the “SEC”) recently voted to propose temporary rules to permit companies to provide equity compensation to certain workers known as “gig” or “platform” workers.

Guest Contributor 10/28/20 Guest Contributor 10/28/20

SEC Proposes Relief from Broker-Dealer Registration for Certain Finders

By Steve Ganis

The SEC recently published in the Federal Register a proposed notice of an exemptive order (the “Proposal”) that would, subject to limitations and conditions discussed below, exempt certain individuals seeking to find investors for private companies and unregistered funds (“Finders”) from federal broker-dealer regulation requirements. Among other things the Proposal would allow Finders to earn commissions or other transaction-based compensation.

Guest Contributor 11/19/19 Guest Contributor 11/19/19

Liquidity for Private Company Securities — Rule 144

By Joshua Bergmann

For early stage private companies that need to effectively utilize available capital, often times attracting talent comes at the expense of issuing shares of stock (or options to purchase shares of stock) of the company through the use of an equity incentive plan.

Marine Bouaziz 4/17/19 Marine Bouaziz 4/17/19

The SEC Confirms the Limited Scope and Nature of Utility Tokens

By Marine Bouaziz and Dan DeWolf

On April 3, 2019, Finhub, the SEC’s Strategic Hub for Innovation and Financial Technology, released the “Framework for ‘Investment Contract’ analysis of digital assets” (the “Framework”) providing principles for analyzing whether a digital asset[1] constitutes an investment contract, and thus a security. The same day, the SEC’s Division of Corporation Finance (the “Division”) published its first No-Action Letter on digital tokens.

Sam Effron 2/22/16 Sam Effron 2/22/16

No Action Letter On Behalf Of Citizen VC

By Dan DeWolf and Samuel Effron

The SEC has finally provided clarity as to how an issuer of securities can conduct a private placement in a password protected web page under Rule 506(b), without it being deemed a “general solicitation” and thereby being subject to the additional requirements imposed by the new Rule 506(c). The guidance has been provided by the issuance of the Citizen VC No Action Letter (the “CVC Letter”), which request was authored by Mintz Levin.

Guest Contributor 1/7/16 Guest Contributor 1/7/16

Benefits of a Regulation A+ Offering

Enacted in June 2015, Regulation A+ allows private companies in Canada and the United States to raise money through general solicitation. Pamela Greene, a Member of Mintz Levin's Corporate & Securities Practice, explains the benefits of a Reg A+ offering over an IPO.