Regulation A is having a moment.
With SEC Chairman Paul Atkins stating that the Commission is looking to “better facilitate retail investor participation in private markets while preserving their protection with appropriate safeguards,” and a 2026 regulatory agenda explicitly built around capital formation, Regulation A is having a moment. Founders with a following are taking notice, and pitch decks increasingly include […]
“One and done” SPV reporting? No, not really
A few months ago, I posted about the received wisdom in the crowdfunding industry thatholds that because an issuer used a special purpose vehicle to handle its offering underRegulation CF, that SPV counted as only one “holder of record” for ongoing reportingpurposes. Therefore, the theory goes, issuers could take advantage of the provision inRule 202(b)(2) […]
“One and done” SPV reporting? Really?
It’s Form C-AR filing season again, and maybe time to discuss an interesting consequence of using a crowdfunding special purpose vehicle (“SPV”). These are used in roughly one quarter of all Regulation CF filings, according to the analysis of our colleagues at Kingscrowd. Everyone in crowdfunding knows that once a company has taken money from […]
AI and Fraudsters are Upending Indicia of Trust in Online Investments
The SEC recently brought an enforcement action against persons who created a fake trading platform for crypto, in which investors were contacted through messaging apps and encouraged to deposit funds in exchange for the crypto products being offered. See, https://www.sec.gov/newsroom/press-releases/2025-144-sec-charges-three-purported-crypto-asset-trading-platforms-four-investment-clubs-scheme-targeted. While investment scams are not new, this scam brings together new elements that upend some […]
SEC Announces Examination Priorities.
On November 17, 2025, the SEC released its annual examination priorities covering all categories of entities under its supervision. These include broker-dealers, investment advisers, FINRA, as well as funding portals operating under Regulation Crowdfunding. Although the list of priorities specific to funding portals is shorter than those for other regulated entities, it still signals the […]
Tokenization Isn’t Magic: Compliance Still Matters in the Digital Asset Space
With recent Congressional developments like the GENIUS Act and the CLARITY Act, the digital asset space appears to be entering a second wave following the initial frenzy of 2021 and 2022 (remember the Bored Ape Yacht Club?). Yet amid the changing landscape, one belief has persisted among some players: the idea that turning an existing […]