Where is the Regulation D Proposal?

The last of the SEC’s six major proposals to ease the burden on smaller public companies has still not been released more than two months after it was announced back on May 23. This proposal, which is supposed to include the right to have limited advertising if offerees include only a new type of “super ...

Feldman Weinstein and Smith Comment Letter Regarding S-3 Proposal

Below is our firm’s comment letter with respect to the SEC’s proposals on the availability of Form S-3 “short form registration” for all reporting companies. The letter has been submitted to the SEC and is available on their web site: Subject: File No. S7-10-07 From: David N. Feldman, Esquire Affiliation: Managing Partner, Feldman Weinstein and ...

Feldman Weinstein and Smith Comment Letter Regarding Rule 144 Proposals

Below is our firm’s comment letter with respect to the SEC’s proposals on Rule 144. The letter has been submitted to the SEC and is available on their web site: Subject: File No. S7-11-07 From: David N. Feldman, Esquire Affiliation: Managing Partner, Feldman Weinstein and Smith LLP July 19, 2007 FELDMAN WEINSTEIN AND SMITH LLP ...

Yes I'm on Facebook

I have been in touch with more and more of my business contacts through Facebook, yes Facebook. They now grant access to anyone, not just college kids posting underage drinking photos. I do believe that it could herald a new era of business networking, so I have embraced it. In fact, I have started a ...

The New SEC Regulation D Proposal – Why We Care

I have had a chance to review the SEC’s proposed overhaul of Form D and proposal to require electronic filing of the form going forward. While you might think this stuff is highly technical and seemingly not that important other than for the form-philes among us (not me friends), in many ways it is. [Note: ...

Our "Summer Reading" Courtesy of the SEC

Greetings blogees from the City of Brotherly Love where I am to visit my issue (as we lawyers say). SEC Division of Corporation Finance chief John White promised back in April that the new proposals to help smaller public companies would be ready for our “summer reading.” True to his word, after the May 23 ...

Is the Rule 415 Issue Still Relevant? (hint: yes)

Some are wondering if the new Rule 144 proposals, in particular shortening the holding period before being able to sell without registration in most cases to six months, essentially moot the entire Rule 415 brouhaha. The short answer: well yes and no. There is no question that shortening the Rule 144 holding period will meaningfully ...