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    Staff Addresses Family Trusts With Multistate Trustees

    When the Securities and Exchange Commission two years ago proposed amendments to Rule 147 and adoption of Rule 147A, I commented on an issue that I foresaw with respect to family and other non-business trusts:

    Uncategorized, compliance and disclosure, family trust, intrastate offering, Rule 147, Rule 147A

    Investment Companies And Intrastate Offerings

    Recently, my eye caught the following statement in the SEC's Intrastate Offering Exemptions: A Small Entity Compliance Guide for Issuers:

    Legislation, Legal History, required to be registered, SEC Rel. No. 33-4434, Section 24d, 26 FR 11896, intrastate offering, Investment Company Act, Rule 147, Rule 147A, Section 3(a)(11)

    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...

    California Securities Laws, intrastate offering, Rule 147, Rule 147A