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Helter Skelter

03/01/16 1:57 PM

#72940 RE: JonnyBGood #72939

They have to file the Form D. Whether not filing the Form D constitutes fraud is another subject. Here's this attorney's take on it...

In a column for the December issue, Alan Parness of Cadwalader, Wickersham & Taft LLP wrote about the enforcement report issued last October by the North American Securities Administrators Association (aka NASAA).

Alan notes that NASAA reported that the states brought more than 250 enforcement actions involving Rule 506 and Regulation D in 2010. Because NASAA didn’t disclose the specific allegations in these actions, Alan did a little digging. He found that Arkansas had brought 12 orders specifically involving Rule 506 and that each of these orders alleged failure to file a Form D in a timely fashion. The orders did not allege fraudulent practices or that the issuer had otherwise failed to comply with Rule 506.

Read more if you like ~> Enforcing Form D Filings – A Misguided State Policy

Like I said, even non-reporting stinky pinkies have to file the Form D. End of story. Ask tpac CEO mckay. He was, allegedly, an attorney. He should know (even though his practice field wasn't securities' law, he should still know). Thanks...

Good day.

Kramden1

03/01/16 2:11 PM

#72944 RE: JonnyBGood #72939

You mean>>>>The Truth Will Actually Be Posted? $TPAC