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Concurrent Public Offerings and Private Placements

4 Integration • The SEC’s integration doctrine was developed to prevent the circumvention of the registration requirements through the separation of a single non-exempt offering into several exempt offerings • Historically, the SEC considered concurrent offerings a potential integration issue and developed a 5 factor test for whether offerings should be

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  Private, Public, Placement, Offering, Concurrent, Circumvention, Concurrent public offerings and private placements

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