Communications with the Public: Rapid Fire
Chapters in this video
- 0:00 Three audience buckets: correspondence, retail, institutional
- 1:22 The 25 retail investor ceiling and rolling 30 day trap
- 2:37 Ingrid's $50 million VIP pass and the closed institutional list
- 3:13 Retirement plan institutional versus retail participant gotcha
- 4:03 Approval rules: principal pre sign off versus written supervisory procedures
- 5:04 Filing timelines for new member firms and established firms
- 5:55 Universal content standards and the three performance projection carve outs
- 7:05 Three year retention, spot checks, and the private placement memorandum trap
- 8:18 Accredited only advertising exception and tombstone exclusions
- 9:07 Rapid fire exam recap
What this video covers
- Why 25 retail investors in any rolling 30 calendar day period is the hard ceiling for correspondence, and how a 26th recipient changes the entire rule set
- The closed list of institutional investors, including the $50 million total assets test for natural persons, and why account status with the firm is irrelevant
- Why a retirement plan can be institutional while its individual participant remains retail, and how to spot that distinction under pressure
- The pre-approval requirement for retail communications by a qualified registered principal before the earlier of use or filing, versus the written supervisory procedures alternative for correspondence and institutional communications
- The three carve outs that allow performance prediction or projection: hypothetical illustrations of mathematical principles, compliant investment analysis tools, and supported research report price targets
- Why excluded from filing never means excluded from the universal content standards, and how the Financial Industry Regulatory Authority (FINRA) spot check still applies
- When public advertising of a private offering is permitted under the accredited investor exemption, and when a tombstone announcement loses its filing exclusion
Read the full lesson, free
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