New Rule 147A And Amendments To Rule 147 Are Now Effective

Last October the Securities and Exchange Commission adopted amendments to Rule 147 to modernize the safe harbor under Section 3(a)(11) and a new intrastate offering exemption, Rule 147A.  See Will New Rule 147A Lead To A Renaissance In California Permit Applications?  These changes took effect on just over a month ago - on April 20, 2017.  The SEC also has published a Small Entity Compliance Guide for Issuers that includes this handy table:


Issuers will, of course, need to comply with state securities law qualification requirements.  If these exemptions prove popular, we may see corporate lawyers rediscovering the blue sky laws.