Rules for Demo Day Organizers

As a follow-up to my previous post Enough Already, We Think We Understand General Solicitation, I discussed a bit about what the companies presenting at demo days and conferences need to think about. What about the entities that are organizing these events, do they need to be 506(b) or 506(c) entities? Are they generally soliciting?

This is the other half of a large question for me as a part of the Seattle Angel Conference. This note that references the Michigan Growth Capital Symposium SEC No-Action Letter is particularly interesting and justifies the organization of these events without falling into the realm of general solicitation. This note doesn’t change the new rules for companies presenting at demo days and other growth company conferences… just is interesting for those organizing this type of conference…

9 See also, Michigan Growth Capital Symposium (SEC No-Action Letter, February 6, 1995) in which the staff concurred that the sponsorship of a symposium to promote access to venture and other capital funding for emerging growth companies did not involve a general solicitation under Rule 502(c) primarily because the targeted mailings were to persons known as accredited investors and no specific financing details were part of the presentations by the growth companies and no private offering materials were distributed at the symposium.

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