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CALIFORNIA CORPORATE & SECURITIES LAW

SEC Staff Declares Performance History Is Not Factual

The Securities and Exchange Commission staff recently issued a series of additional Compliance and Disclosure Interpretations with respect to what might constitute a “general solicitation” under Regulation D. ¬†These interpretations illustrate the logical contortions that must be endured when trying to regulate speech. ¬†After admitting that an issuer may disseminate factual information about itself, the…

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