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Podcast: Syndication Law & The Private Placement Memorandum Attorney
Episode: SEC and State Compliance Part 5: Understanding Commingling for Syndication Sponsors
Description: When working on ensuring your Regulation D offering is compliant with the SEC and state regulators, you're likely to encounter the concept of 'commingling'. As the name suggests, commingling refers to the act of mixing funds from different sources, something that's frowned upon by regulators such as the SEC and state regulators. Specifically, they're against the idea of using funds from one investment pool to fund another, even temporarily. Sure, it might seem like an easy solution when you're short on cash for a new investment opportunity, but it's a practice that can land you in hot water. At...