Finders: Recommendations to the SEC

The SEC’s Advisory Committee on Small and Emerging Companies recently issued recommendations regarding the regulation of finders. If you are not familiar with the rules, the SEC takes a very narrow view of who can help companies find investors without having to register as a broker-dealer. Broker-dealer registration is so onerous that people won’t engageContinue reading “Finders: Recommendations to the SEC”

Rule 701 Math: The 15% of Shares Test

If you are administering a private company stock option plan, you need to do what is referred to as “the Rule 701 math” before every grant of stock options or equity awards. What is “the Rule 701 math”? Rule 701 contains a set of mathematical limitations on how many shares of stock you can offer service providersContinue reading “Rule 701 Math: The 15% of Shares Test”

Angel Groups and the SEC

The SEC recently issued guidance on angel groups and the general solicitation and general advertising of private company securities offerings. General solicitation and general advertising of private company securities offerings is a hot area. The JOBS Act allows companies that are raising money solely from accredited investors to generally solicit and generally advertise their offerings. However,Continue reading “Angel Groups and the SEC”

Why write a book on angel investing?

As the President of Seattle Angel, I’ve worked with a fair number of new angel investors over the years. I continually found that investors were exploring a personal interest and an investment return when they approached angel investing. This is a little different than a pure financial investor as a pure financial investor isn’t necessarilyContinue reading “Why write a book on angel investing?”

The “Pre-Existing, Substantive Relationship”

The SEC recently issued guidance on what constitutes a “pre-existing, substantive relationship.” The guidance is helpful for companies raising money for a number of reasons. The SEC guidance is especially helpful because there has been a fair amount of uncertainty about how to make sure a securities offering is not considered to have been generally solicited or generallyContinue reading “The “Pre-Existing, Substantive Relationship””

Online Portals, Rules 506(b) & (c), and CitizenVC

The SEC recently issued an important no-action letter for online portals, and for other issuers of securities (including startup companies), trying to raise money in compliance with the SEC’s new 506(b) and 506(c) rules. We can thank Dan DeWolf from Mintz Levin and his colleagues for obtaining this guidance from the SEC. Dan wrote a postContinue reading “Online Portals, Rules 506(b) & (c), and CitizenVC”