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CALIFORNIA CORPORATE & SECURITIES LAW

Is Forced Speech In Responding To Staff Comment Letters Inaccurate Speech?

In 2014, the Securities and Exchange Commission announced that all comment letters would request that the issuer include the so-called “Tandy Letter”.  Thus, all staff comment letters include a request for a written statement in haec verba: The company is responsible for the adequacy and accuracy of the disclosure in the filing; Staff comments or…

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Wager, Insurance, Bucketing or Swap?

In yesterday’s post, I mentioned Professor Joan Heminway’s recent essay on crowd funding.  She notes that some crowd funding arrangements may “may look less like investment instruments commonly known as common stock or debentures, and more like loans, gambling bets, rights to consumable products or services or charitable or other nonprofit donations.”  See “What is…

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