Key takeaways:

• The SEC is reviewing the federal securities laws that (i) limit the number of shareholders of record that a private company may have before it becomes subject to public company reporting requirements and regulation; and (ii) prohibit the use of “general solicitations” in private placements. 
• An increase in the shareholder threshold and a relaxation or elimination of the general solicitation prohibition could, in the future, afford private companies greater flexibility to pursue growth for longer periods of time unfettered by public company reporting requirements and regulation. 
• We will continue to monitor and report on relevant developments relating to the SEC's review.