U.S. Regulation D Securities Offerings for Small Business

It was this concern that prompted Regulation D, aDPO since an Investment Banker does usually not
special exemption that became effective April 15,underwrite the offering. A SCOR offering is an
1982. It's not just another exemption, but ratherideal format for executing a limited Internet DPO.
one of the key exemptions for small businessThink of a SCOR offering as a quasi-public private
that want to raise money by selling stock to theoffering.
general public. It is also considered a form ofA SCOR candidate may raise as much as $1
taking a company public without the burden andmillion within a 12-month period with a minimum
expenses of a full registration process with thestock price of $5. Typically, the prospective
SEC such as in a traditional Initial Public Offering.SCOR candidate will set a minimum amount of
Regulation D consists of six basic rules. The firstcapital to be raised to ensure that sufficient funds
three are simply basic rules; they are concernedwill be available for growth and development
with definitions, conditions, and notification. Rulebefore any of the funds are accessible for
501 covers the definitions of the various termscompany use.
used in the rules. Rule 502 sets forth theWhile a SCOR offering does not contain the
conditions, limitations, and informationsubstantial costs usually associated with larger
requirements for the exemptions in rules 504,public offerings, it is a prime candidate for an
505, and 506. Rule 503 contains the SECInternet DPO (On-line Direct Public Offering), which
notification requirements. The last three rules dealtypically costs much less and provides a small
with the specifics of raising money. Rule 504company with an effective means by which to
generally pertains to securities sales up to $1raise capital. The filing, which consists of a form
million. Rule 505 applies to offering from $1 millioncalled Form U-7, is exempted from the provisions
to $5 million. Rule 506 is for securities offeringsof the SEC Act of 1933 under Regulation D, which
exceeding $5 million.means that the DPO candidate will not have to file
Regulation D contains the type of exemptionsa full registration statement with the SEC.
that many small businesspersons have beenHowever, as with any public company, compliance
looking for. These exemptions can easily be usedwith antifraud and personal liability provisions of
in private placements or "limited public offerings".the SEC Act of 1933 is a requirement.
Thus, a Regulation D private placement document,SEC Filing (U-7)
better known as the Private PlacementDPO candidates are required to complete and file
Memorandum, has been regarded as one of thea FORM U-7 that has been designed with idea in
most workable exemptions for small offerings.mind that non- securities attorney can complete it;
While Regulation D offerings can provide a capitalnevertheless, it will most likely require expert
formation solution for a small business (the goodassistance. Furthermore, in some cases, 2 years
news), it does have some legal limitations (the notof audited financial statements are required and
so good news). There are strict limitations placedshould be included with the Form U-7 filing.
how the solicitation process is done on theseBlue Sky; State Filing (SCOR)
stock sales (securities) to the public as well asRegulations at both federal and state levels must
suitability standards that are imposed on the typebe complied within a SCOR-based DPO as well as
of investors. These limitations drastically reducewith any IPO. The State regulations are called Blue
the number of private placements that areSky laws. Blue Sky laws were designed to
successful. A Regulation "A" offering (anotherprotect investors from "unscrupulous" issuers of
exemption) has a higher probability of successstock. Since its inception in 1987, SCOR filings
based on a more dynamic SEC exemption rule.have been adopted in 42 states. Some states
This Exemption will be discussed in future articles.may require minimum amounts to be raised
SCORbefore the DPO candidate may access the raised
The Small Corporate Offering Registration, bettercapital.
known as SCOR, (falls under Regulation D) isStay tuned for more information on this topic and
designed to assist small companies in theirfurther general articles on capital raising
capitalization by issuing stock directly to the public.alternatives for small business.
This process is called a Direct Public Offering or