Comments on Proposed Rules
Commenters were generally supportive of the proposed non-public submission process for Regulation A offerings.270 One commenter recommended keeping all filings confidential other than the final qualified version and possibly any interim version
269 See proposed Rule 252(f).
270 BIO Letter; McCarter & English Letter; Paul Hastings Letter; Richardson Patel Letter.
actually used in conjunction with solicitation materials.271 Another commenter recommended requiring the inclusion of a legend on non-public offering statements so that the confidentiality of such submissions would be automatic, without the need for a separate confidentiality request,272 while another commenter recommended treating the proposed non-public submissions the same way that draft registration statements are treated under Title I of the JOBS Act.273