What is a rolling close?
The SEC permits multiple closes. Though, the platform could decide not to allow them. StartEngine Capital does permit rolling closes, provided the following conditions:
- The issuer must disclose on the Form C that there may be an early initial closing, followed by multiple closings. Note that the multiple closings cannot go past the deadline date (Unless an amendment is filed to extend the deadline) and cannot go over $1.07M. This is a standard part of the "StartEngine Investment Process" filed with every Form C, so that each issuer has the option, should they so choose.
- No amendment is needed for a multiple close, if the issuer discloses this in the Form C. If they do not disclose this, they would have to file an amendment.
- Issuer/platform must follow the regular requirements for conducting a close, when doing multiple closings.
- Only one Form C-U is needed, within 5 days of the offering deadline. No Form C-U is needed for each close.