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When to Switch from 506(b) to 506(c)—And Why It Matters with Dugan Kelley

What’s the real risk behind accepting investor referrals—and what could cost you hundreds of thousands without you realizing it?

In this episode, Dugan Kelley clarifies the rules around raising capital under the 506(b) exemption. He breaks down what counts as general solicitation, when a preexisting relationship is required, and how word-of-mouth referrals can create unexpected liability. They also address growing confusion around registered broker-dealers, finder’s fees, email marketing boundaries, and the future of accreditation rules. If you’ve ever questioned how to stay compliant in your…

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