The February 2016 column1 reviewed the provisions of Rule 506(b)2 and recent Securities and Exchange Commission (SEC) guidance on Rule 506(b) Internet offerings. This column will review the applicable SEC no-action letters and releases.
Letters and Releases
The IPONET, SEC No-Action Letter (July 26, 1996), extended the staff’s ruling in H.B. Shaine & Co., SEC No-Action Letter (May 1, 1987), to private offerings in a password-protected page of IPONET’s website, accessible only to accredited investors who have previously qualified under the H.B. Shaine procedure. Such procedure involved the completion of a generic questionnaire and the elapse of a sufficient period of time before the inception of a private offering to which a new accredited investor would be directed.
