The “Bad Actor” Amendments: Private Issuer Compliance with Rule 506

Simon RivelesBad Actor, General Solicitation, Hedge Funds, Jobs Act, Private Fund Exemption, Private Placement, Reg D Rule 506

By Simon Riveles and Peter Tyson On July 10, 2013, the Securities and Exchange Commission (SEC) adopted amendments to Rule 506 of the Securities Act of 1933 to disqualify securities offerings relying on the Rule 506 exemption that involve certain “felons and other ‘bad actors’”.  The final amendments (the Final Rules) went into effect on September 23, 2013 (the Effective Date) and apply to all …