New C&DIs target Regulation D and Rule 147
The SEC’s Division of Corporation Finance issued a set of new and revised Compliance & Disclosure Interpretations covering various aspects of Regulation D and Securities Act Rule 147. Regulation D had been significantly updated by provisions in the Jumpstart Our Business Startups (JOBS) Act and by the Commission’s implementing rules release. The Commission more recently adopted changes to Rule 147. The new C&DIs include eight substantive revisions or additions plus 22 revisions the Division characterized as non-substantive.