> why do you assume they haven't spoken to an attorney?
Accredited investor requirements are NOT “a good faith requirement,” and there absolutely are ways “for Purism to validate your accredited investor status.” This statement, in a general solicitation e-mail no less, would not get sign off from any competent securities counsel.
Their fundraising site is tighter but still leaky. The notes are governed by Washington law [1], for example, which means e.g. they can’t ignore investor protections for non-Americans (as they claim). Also, other jurisdictions have securities laws—it is incorrect to claim if “not a United States citizen there is no restriction to invest” [2].
Finally, they are selling these notes through their store, which offers check out with Stripe. I was able to get to a credit-card checkout page. That’s a no-no on multiple levels.
(If you want to do something like this properly, look into Tier 1 Reg A+ offerings [3]. There are turnkey providers, e.g. StartEngine [4], though I'm skeptical of anyone requiring large up-front payments.)
You asked (someone else) why one might "assume they haven't spoken to an attorney" [1]. I answered that. This is not the work product of competent securities counsel. (The promissory note per se looks fine. But it’s from 2021.)
As presently marketed, this has a high probability of being an illegal securities offering. If the issuer knows it's insolvent and isn't disclosing that, it could even be fraud.
Anyone familiar with the rules and regulations in that area will be able to tell you this is clueless work. If they consulted with an attorney who signed off on this, said attorney needs to be fired.
Source: am familiar with the rules and regulations in that area.
Accredited investor requirements are NOT “a good faith requirement,” and there absolutely are ways “for Purism to validate your accredited investor status.” This statement, in a general solicitation e-mail no less, would not get sign off from any competent securities counsel.
Their fundraising site is tighter but still leaky. The notes are governed by Washington law [1], for example, which means e.g. they can’t ignore investor protections for non-Americans (as they claim). Also, other jurisdictions have securities laws—it is incorrect to claim if “not a United States citizen there is no restriction to invest” [2].
Finally, they are selling these notes through their store, which offers check out with Stripe. I was able to get to a credit-card checkout page. That’s a no-no on multiple levels.
(If you want to do something like this properly, look into Tier 1 Reg A+ offerings [3]. There are turnkey providers, e.g. StartEngine [4], though I'm skeptical of anyone requiring large up-front payments.)
[1] https://puri.sm/wp-content/uploads/2021/07/purism-convertibl...
[2] https://puri.sm/ir/convertible-note/
[3] https://www.bartonesq.com/news-article/reg-a-offerings-faqs/
[4] https://www.startengine.com/blog/regulation-a-what-entrepren...