I. Introduction
Sometimes the unexpected happens. But preparing for the unexpected is the essence of the compliance function. The failure to effectively prepare for risks unrelated to your core business can be disastrous. A seemingly innocuous compliance breach could disqualify your firm from participating in a private offering of securities under Rule 506(d), known as the “Bad Actor” Disqualification. Being a Bad Actor can have detrimental, if not fatal, consequences for your firm – hence the critical importance of making known certain unknowns. Continue reading