When Should You File Your Form D

The way the Form Ds work is that you’re required to file the Form D with the SEC within 15 days of the first sale of your syndication. And that to me means money in the… I would do it when money hits the account. When money comes in the account and they sign the paperwork, that’s what I would use. Arguably, it’s when you countersign the subscription agreement, but let’s not cut it that close. And then each state requires you to file a copy of that Form D that you filed with the SEC. A copy of that Form D gets filed to each and every state where you have an investor. And that is due within 15 days of the first sale in that particular state. My SEC filing may be due today, but maybe my first sale in Montana doesn’t happen for… until June 1st. Then my Form D copy to Montana is going to be due on June 15th. So there’s one for each and every state.

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