September 15, 2013
To Elizabeth M. Murphy
During the Tuesday's Advisory Committee Meeting on Small and Emerging Companies, would you please include the following very critical questions:
a, Are investors for Equity Crowdfunding allowed to use Creditcards to
purchase shares ?
Today's Donation & Rewards based Crowdfunding is 95% based on
b, Will Accredited and Foreign investors be allowed to invest and what
would be their limitations ? HR3606 Title III did not address it !
c, Regarding the "TWO YEARS Audited Financials":
Auditing back for two years is onerous and cost prohibitive from small
to midsize companies. Most of the files are already archived and two
years old data irrevelent when we already have the most recent Audited
Financial Statements to attest to the Issuer's credibility and financial
Last Fiscal Year's Audited and the year's before prepared by a CPA would
be sufficient (which most companies already have) to evaulate any firm's
d, Most CPA-s we are talking to asking the question: what are we auditing
Is it Risk Assessment or Red Flag Reviews or Investment Reviews ?
These needs to be clarified by the Commission. If we make the up-front
cost to enter a Crowdfunded IPO, to expensive for Issuers, it will kill
the market !
..... and finally, please ask the Commission to expedite that Regulations for HR3606 Title III, Crowdfunding exemptions. Thousands of Small Issuers and many Crowdfunding portals are bleeding away.
And that is contrary to the spirit of that none partisan JOBS Act !
Respectfully submitted by,