SEC Proposes Amendments to Disqualify “Bad Actors” from Rule 506 Private Placements

June 06, 2011
In order to implement Section 926 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Securities and Exchange Commission recently proposed amendments to Rules 501 and 506 of Regulation D as well as to Form D to disqualify “bad actors” from participating in private placements of securities under Rule 506. In this update, we review the key provisions of the proposed amendments and provide our thoughts on the commentary likely to be made regarding these amendments.