Partner Christine Schleppegrell was quoted in a Private Equity Law Report article discussing the US Securities and Exchange Commission’s (SEC’s) No Action Letter, including the historical context of Regulation D offerings prompting the safe harbor; why, how and for whom 506(c) offerings will become more common; potential issues fund managers need to grapple with in 506(c) offerings; and where the No Action Letter fits in the SEC’s broader agenda.
“One of the material benefits of the No Action Letter guidance that may spur an increase in 506(c) offerings is that it will likely facilitate more direct outreach without using intermediaries (e.g., placement agents) that have historically held the keys to accessing investors they know are already qualified and verified,” Christine said. “If advisers can reach out to investors without having to form a preexisting substantive relationship, then that will help some advisers to remove that middle piece,” she added.
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