Regulatory Update: SEC Reg CF and NEW Form C Filing FAQ
In light of the Reg CF rule amendment that became effective on March 15, 2021, the SEC released an Announcement regarding new Form C guidance in an FAQ format. Below is a link to the SEC Announcement and referenced Reg CF Rule Amendment. The FAQ guidance addresses the following questions:
Is a crowdfunding vehicle required to file its own Form C, separate from the Form C filed by the crowdfunding issuer?
Does the crowdfunding vehicle need to have its own filer identification number (called a “Central Index Key” or “CIK” number) and EDGAR access codes?
What information about the crowdfunding vehicle is required to be provided in the XML-based portion of the Form C?
The crowdfunding vehicle and its principal executive officer or officers, its principal financial officer, its controller or principal accounting officer and at least a majority of the board of directors or persons performing similar functions are required to sign the Form C. How should those signatures be provided?
SEC Announcement here: https://www.sec.gov/corpfin/announcement/staff-guidance-edgar-filing-form-c
Regulation Crowdfunding Amendment: Release No. 33-10884 https://www.sec.gov/rules/final/2020/33-10884.pdf
