What Is 15c2-12 `Reasonable Diligence?'

While the SEC's MCDC Initiative has provided some clarity with regard to materiality and confirmed that the reasonable diligence standard of Rule 15c2-12 applies to both negotiated and competitive deals, no clarity has been offered with regard to the extent of the reasonable diligence obligations of those participating in competitive deals, as co-managers, syndicate members or selling dealers.

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