On October 30, the U.S. Securities and Exchange Commission (“SEC”) adopted final rules in the form of Regulation Crowdfunding to implement the securities-based crowdfunding exemption in Section 4(a)(6) of the Securities Act of 1933, as amended (“1933 Act”), as mandated by Title III of the Jumpstart Our Business Startups Act (“JOBS Act”). Regulation Crowdfunding will become effective on May 16, 2016.

Part I of this three-part client alert, provided a general overview and summary of Regulation Crowdfunding. Part II focused specifically on requirements imposed on issuers seeking to offer securities under the new rules. This Part III will focus on the requirements imposed on intermediaries.