On December 1, 2020, New York Attorney General Letitia James announced updates to the New York state securities laws.  Among them are changes to the state’s blue sky filings requirements,…

When making a private fund offering and you don’t know which blue-sky laws apply, who you gonna call? . . . Hardin Compliance!  Although private fund managers know they have…

Check out this recent Hardin contribution to the February 2020 issue of the National Society of Compliance Professionals’ (NSCP) Currents newsletter: In “Form ID, Form D, Blue Sky…Oh My!“, Denise Alfieri, Managing…

As a general rule, private funds that rely on an exemption from registration under Rule 506 of Regulation D of the Securities Act (including offshore funds) have to submit a…

In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7.  As…

In this installment of Hardin’s “Devil is in the Details” series on state blue sky filings for private fund managers, we dig into common exemptions from blue sky filing requirements. …

In Part 6 of Hardin’s “Devil is in the Details” series on state blue sky filings, we shine the spotlight on Termination and Withdrawal Notice filings.  Links to other articles…

As noted in Part 2 of this series of articles on blue sky filings, private funds (“issuers”) relying on an exemption from registration of their offerings are required to submit…

  With laws varying by state, keeping up with blue sky filing requirements can be a headache.  Many state laws don’t mention amendments (or renewals), but does that mean they…

Like other private fund managers, those advising offshore funds offered in the United States (“U.S.”) routinely rely on Regulation D (“Reg D”) to avoid registration with the SEC under the…