When the SEC adopted the Rule 506(c) amendment allowing general solicitation in certain Regulation D offerings, it also proposed a number of changes to Regulation D. The Federal Regulation of Securities Committee of the American Bar Association' s Business Law Section, recently submitted a very thoughtful comment letter on those proposed changes. It's available here.

I have been a member of the Federal Regulation of Securities Committee and several of its subcommittees for over two decades. Almost all of the country's top securities lawyers are members. (I'm not sure why they let me join.) I don't always agree with the committee's views, but its positions are always thoughtful and well-reasoned. This letter is no exception (and, in this case, I happen to agree with most of it). It's worth reading.

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Photo of Colleen Baker Colleen Baker

PhD (Wharton) Professor Baker is an expert in banking and financial institutions law and regulation, with extensive knowledge of over-the-counter derivatives, clearing, the Dodd-Frank Act, and bankruptcy, in addition to being a mediator and arbitrator.

Previously, she spent time at the U. of…

PhD (Wharton) Professor Baker is an expert in banking and financial institutions law and regulation, with extensive knowledge of over-the-counter derivatives, clearing, the Dodd-Frank Act, and bankruptcy, in addition to being a mediator and arbitrator.

Previously, she spent time at the U. of Illinois Urbana-Champaign College of Business, the U. of Notre Dame Law School, and Villanova University Law School. She has consulted for the Federal Reserve Bank of Chicago, and for The Volcker Alliance.  Prior to academia, Professor Baker worked as a legal professional and as an information technology associate. She is a member of the State Bars of NY and TX. Read More

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