Goodwin Procter Alert - Using the Web to Match Private Companies and Potential Investors: SEC No-Action Letters Open a Door, but Questions Remain

Goodwin Procter issued a Client Alert that analyzes two recent SEC no-action letters concerning whether website operators that seek to match early stage companies with accredited investors must register as broker-dealers.  Each website operator is an investment adviser that organizes special purpose investment funds via its website.  In each case, the SEC staff stated that it would not recommend enforcement action if the website operator did not register as a broker-dealer.