Deborah Froling, a partner in Kutak Rock's Washington office, authored in collaboration with the 506(c) Working Group, a bylined article titled "506(c) Offerings: Practical Guidance for Broker-Dealers and Registered Investment Advisers," published March 24 in DI Wire.
The article discusses how rule 506(c) allows issuers to conduct their private placement offerings utilizing general solicitation to find investors on the condition that those issuers have taken reasonable steps to verify the accredited investor status of their investors.
In the article, Deborah also explores some of the procedures and policies that broker-dealers and registered investment advisers should take into consideration when providing issuers with such written confirmation.
Deborah is a Business, Corporate, and Securities attorney with extensive experience in public and private offerings of debt, equity and convertible securities as both issuer's and underwriter's counsel primarily for real estate companies. She has closed public and private debt and equity offerings, primarily for REITs and other real estate companies, as well as non-traded equipment finance and oil and gas companies, and business development companies. She has also structured and closed numerous tenant in common syndications and has worked with public and private company clients providing general corporate counseling and advising on periodic and annual reporting and other SEC disclosure requirements.