Be sure to read Joe Bartlett's new post on VC Experts, QUIET 506 - A Study in Irony.
Joe's provocative take is that it almost doesn't matter whether the SEC moves on 506(c). (Translation for those who haven't memorized the shorthand references: it almost doesn't matter whether the SEC finalizes rules, as required under the JOBS Act, to permit startups to advertise for angel investors.)
I may be exaggerating Joe's view, but only slightly:
"The fact . . . is that the ban (on general solicitation and general advertising) has been, as a practical matter, history for a number of years by virtue of the Two-Step process. Quiet 506(b) is in fact a very noisy Rule 506 in the real world and platforms such as AngelList, Circle Up, and others are already taking advantage of the internet to raise capital for emerging growth companies … and have been for some time. The advent of the Title II Regs, in that sense, is anti-climactic. We are already there, courtesy of the internet, and the trick now is to adjust to the new reality in the legal sense of the word."
To read the original article: The JOBS Act: More On Where We Are With General Solicitation | The VC Experts' Buzz | VC Experts
