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:
                                Staff Addresses Family Trusts With Multistate Trustees
                                
                                
                                    
                                    
                                          Posted on September 26, 2017
                                    
                                    
                                
                            
                            
                                Investment Companies And Intrastate Offerings
                                
                                
                                    
                                    
                                          Posted on July 10, 2017
                                    
                                    
                                
                            
                            Recently, my eye caught the following statement in the SEC's Intrastate Offering Exemptions: A Small Entity Compliance Guide for Issuers:
                                New Rule 147A And Amendments To Rule 147 Are Now Effective
                                
                                
                                    
                                    
                                          Posted on June 02, 2017
                                    
                                    
                                
                            
                            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...


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