Rule 504: a distinct Regulation D pathway
Rule 504 may be available for eligible issuers offering up to the current rule limit during a 12-month period. The SEC increased that limit to $10 million in 2021. State registration, qualification, disclosure or exemption requirements may still be significant.
Availability, solicitation, resale status and required disclosure depend on the facts and the state-law route used. A generic PPM cannot establish compliance. Current federal and state requirements should be confirmed by counsel before reliance.