Rule 415 - You Heard it Here First..well after Dow Jones..
At the San Diego PLI conference, SEC Corporation Finance Deputy Director Shelley Parratt was the first to announce the new internal registration guidelines this evening. The standard will be one-third of the non-affiliate stock, below which you're probably OK, and above which they are very willing to entertain arguments that those seeking to register do not meet the test of being an underwriter. The next registration for the same investors, it appears, must wait for 6 months after the PIPE or, if earlier, 60 days after substantially all the shares are sold in the first registration. I'm sure we'll be hearing lots more in the next few days. Bloomberg News, I know, is covering this extensively. More to come when I have it...

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