Integration Safe Harbors
Rule 147/147A. Rules 147 and 147A have identical integration safe harbors, according to which an intrastate offering will not be integrated with another offering if one of the following is true:
• The other offering ends before the intrastate offering starts
• The other offering starts after the intrastate offering ends and the other offering is a registered offering, Reg A offering, Reg S offering, or crowdfunding offering
• The other offering starts more than six months after the intrastate offering ends
SEC Rules 147(g) and 147A(g)
Regulation A. According to Regulation A’s integration safe harbors, a Reg A offering will not be integrated with another offering if one of the following is true:
• The other offering ends before the Reg A offering starts
• The other offering starts after the Reg A offering ends and the other offering is a registered offering, Reg S offering, or crowdfunding offering
• The other offering starts more than six months after the Reg A offering ends
These safe harbors are the same