Ed Condon asked 2 years ago
My firm currently offers a “Security Exempt from Registration under Reg D” (506c) to Accredited Investors. (i.e. “Lane 3”) This investment throws off a very high rate of return; but, it is in the form of ordinary income. The natural home for this investment would be tax free / tax deferred accounts. However, our legal counsel has advised us against taking in more that 24.99% in ERISA assets. Apparently, 25%+ in ERISA money opens a Pandora’s Box of ERISA compliance issues. I have two questions: 1) Have you found a solution for taking in >24.99% into a Security Exempt from Registration under Reg D whereby ERISA compliance is manageable? 2) Does your affiliated law firm set up Reg A Securities? Thanks.