Compliance Guide: Disqualification of Felons and Other "Bad Actors" from Rule 506 Offerings

In 2013, the SEC introduced "bad actor" disqualification provisions under Rule 506 of Regulation D, implementing Section 926 of the Dodd-Frank Act. This compliance guide provides a comprehensive look at how these provisions impact issuers seeking to rely on Rule 506 exemptions, covering disqualifying events, exceptions, waiver processes, disclosure requirements, and transitional considerations.