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In August, Eliza Fromberg was quoted in an article, “SEC Staff: Reg D Issuers Can Safely Provide Factual Business Information,” in ACA Insight. In the article, Fromberg discusses how the SEC’s Division of Corporate Finance provides some helpful clarification for private fund advisers seeking to disseminate information without making a general solicitation. Fromberg says that to avoid a general solicitation, the relationship between the adviser and the investor must exist before the adviser begins participating in the offering.
