SEC Issues New CD+Is Regarding Rule 506 “Bad Actor” Disqualifications

Summary: Earlier this week, the SEC’s Division of Corporation Finance updated its Compliance and Disclosure Interpretations to add 14 new interpretations regarding the application of the "bad actor" disqualifications from Rule 506 private placements. These CD+Is clarify the final rules approved by the SEC disqualifying securities offerings from relying on the safe harbor from registration provided by Rule 506 of Regulation D if felons or other specified “bad actors” are involved in the offering.