b'someonefromdoinganunregisteredpromissorynoteofferingto Washington investors. The states seem far more likely to investigate smaller securities infractions.How Failures Occur and How You Can Avoid Them People who try to draft their own offering documents often dont realize thatfederalandstatefilingsarerequiredtoclaimtheexemption,and inadvertently end up with no exemption! On the flip side, many issuers pay attorneys considerable fees to have their offering documents professionally drafted and then blow their exemption by failing to notify their attorneys when they make a sale to an investor from a new state so the Blue Sky notices can be timely filed!!! Make sure you dont fall into either of those traps.Issuers need to understand that compliance with the Form D and Blue Sky filing requirements and deadlines are their responsibility. While an attorney can draft the documents, help structure the offering and advise the issuer regarding the rules associated with the exemption, it is ultimately up to the issuer to make sure its offering and actions comply with all of the legalrequirementsforitssecuritiesexemptionincludingtherequired filings. The attorney who drafts the documents and files the Form D and Blue Sky notices is generally not involved with raising money from investors. Thus, they have no way of knowing when the issuer breaks impounds or makes a sale to a resident from a new state, triggering the typical 15-day 88'