I thought your book was terrific, and my only criticism regards how I could not find any discussion regarding the new JOBS Act broker-dealer exemption found in Section 4(c)(1) of the Securities Act.
You write: "In a Regulation D, Rule 506 securities offering, an issuer may sell his or her own securities in any state without: a) registering the securities offering, or b) being registered with the SEC or any state as a broker-dealer. Anyone else who is compensated for selling securities on behalf of the issuer is not exempt from registration."
I would have like to have seen more discussion of Rule 3a4-1 under the Exchange Act addressing the issuer exemption, and then, a "c)" in connection with the above-quoted passage that discusses the JOBS Act exemption I referred to above.
Other than these minor quibbles, I really admire this work as I think that it does a good job of giving basic information to people about the syndication process. As a syndication attorney myself, I admire anyone who can do that in a way that clients can understand.
- Roland Wiederaenders (email@example.com) - Apr 26, 2023 - Reviewed on Google