Regulatory: The JOBS Act and materiality determination in private placements
As has been recently reported, the Jumpstart Our Business Startups (JOBS) Act has been signed into law.
June 13, 2012 at 05:05 AM
7 minute read
The original version of this story was published on Law.com
As has been recently reported, the Jumpstart Our Business Startups (JOBS) Act has been signed into law. The JOBS Act is designed to encourage companies to create jobs by lowering hurdles to going public and complying with the laws governing public companies, and by facilitating the ability of companies to conduct private placements to finance their businesses.
One way in which the JOBS Act facilitates private placements is by requiring the Securities & Exchange Commission (SEC) to remove the current ban on general solicitation or advertisements, including social media, in private placements of securities, provided that all purchasers in the private placement are “accredited investors.” This change, when it becomes effective, will allow greater exposure to investments for a wider range of potential investors.
The ability to solicit a wider range of potential investors will bring with it some additional challenges for companies conducting private placements. In the past, companies conducting private placements often solicited investments from a small group of sophisticated investors who were well versed in making such investments.
As companies expand their solicitation efforts to investors who are potentially less sophisticated, extra care should be taken to ensure that all material information is available to potential investors, particularly by ensuring that the private placement memorandum contains the information material to investors' decision-making process.
In a private placement with all accredited investors, there are no specific disclosure requirements under the securities law. However, companies conducting such a private placement must look to the anti-fraud provisions of the securities law, including related case law, and to SEC guidance. These sources indicate that in determining whether information is material and should be disclosed to potential investors, companies must look at what information a reasonable investor would need to make an informed decision.
In this regard, the applicable cases make it clear that companies must look at the total mix of the information, and consider what total mix of information , either through a disclosure document, the due diligence process, or just by general access to the information, the investor needs to make an informed decision. These same cases decline to provide any bright-line test.
So, it remains a matter of judgment as to what would be important to investors, but companies should be particularly careful to ensure that investors have access to information about material or recent developments regarding the issuer, and that the information is up-to-date at the time of the sale.
Companies also should exercise caution around the use of financial projections in conducting a private placement, as the desire or advisability of using financial projections will likely increase as companies act to solicit a broader range of investors. The use of financial projections subjects companies to increased risk because companies often fail to adequately disclose the assumptions related to the projections. Disclosing financial projections without robust disclosure of the assumptions could be misleading, and could create liability for companies and their directors and officers.
In short, companies should ensure that they disclose the material assumptions and include good risk factor disclosure. Good risk factor disclosure does not include risk factors that are merely boilerplate, but requires that companies include those risk factors that actually describe the issues that may undermine the financial projections.
While the JOBS Act brings with it enhanced opportunities for companies to access capital through private placements, companies will need to be extra vigilant in ensuring that they provide investors participating in the offering with the information they need to make a fully informed decision.
As has been recently reported, the Jumpstart Our Business Startups (JOBS) Act has been signed into law. The JOBS Act is designed to encourage companies to create jobs by lowering hurdles to going public and complying with the laws governing public companies, and by facilitating the ability of companies to conduct private placements to finance their businesses.
One way in which the JOBS Act facilitates private placements is by requiring the Securities & Exchange Commission (SEC) to remove the current ban on general solicitation or advertisements, including social media, in private placements of securities, provided that all purchasers in the private placement are “accredited investors.” This change, when it becomes effective, will allow greater exposure to investments for a wider range of potential investors.
The ability to solicit a wider range of potential investors will bring with it some additional challenges for companies conducting private placements. In the past, companies conducting private placements often solicited investments from a small group of sophisticated investors who were well versed in making such investments.
As companies expand their solicitation efforts to investors who are potentially less sophisticated, extra care should be taken to ensure that all material information is available to potential investors, particularly by ensuring that the private placement memorandum contains the information material to investors' decision-making process.
In a private placement with all accredited investors, there are no specific disclosure requirements under the securities law. However, companies conducting such a private placement must look to the anti-fraud provisions of the securities law, including related case law, and to SEC guidance. These sources indicate that in determining whether information is material and should be disclosed to potential investors, companies must look at what information a reasonable investor would need to make an informed decision.
In this regard, the applicable cases make it clear that companies must look at the total mix of the information, and consider what total mix of information , either through a disclosure document, the due diligence process, or just by general access to the information, the investor needs to make an informed decision. These same cases decline to provide any bright-line test.
So, it remains a matter of judgment as to what would be important to investors, but companies should be particularly careful to ensure that investors have access to information about material or recent developments regarding the issuer, and that the information is up-to-date at the time of the sale.
Companies also should exercise caution around the use of financial projections in conducting a private placement, as the desire or advisability of using financial projections will likely increase as companies act to solicit a broader range of investors. The use of financial projections subjects companies to increased risk because companies often fail to adequately disclose the assumptions related to the projections. Disclosing financial projections without robust disclosure of the assumptions could be misleading, and could create liability for companies and their directors and officers.
In short, companies should ensure that they disclose the material assumptions and include good risk factor disclosure. Good risk factor disclosure does not include risk factors that are merely boilerplate, but requires that companies include those risk factors that actually describe the issues that may undermine the financial projections.
While the JOBS Act brings with it enhanced opportunities for companies to access capital through private placements, companies will need to be extra vigilant in ensuring that they provide investors participating in the offering with the information they need to make a fully informed decision.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllUS Reviewer of Foreign Transactions Sees More Political, Policy Influence, Say Observers
Pre-Internet High Court Ruling Hobbling Efforts to Keep Tech Giants from Using Below-Cost Pricing to Bury Rivals
6 minute readPreparing for 2025: Anticipated Policy Changes Affecting U.S. Businesses Under the Trump Administration
Senate Panel Postpones Vote on Reconfirmation of Democrat Crenshaw to SEC
Trending Stories
- 1Call for Nominations: Elite Trial Lawyers 2025
- 2Senate Judiciary Dems Release Report on Supreme Court Ethics
- 3Senate Confirms Last 2 of Biden's California Judicial Nominees
- 4Morrison & Foerster Doles Out Year-End and Special Bonuses, Raises Base Compensation for Associates
- 5Tom Girardi to Surrender to Federal Authorities on Jan. 7
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250