July 6, 2010
I am writing to express my support for petition 4-605 to exempt small securities offerings from registration. As an investor, I am excited by the possibility of supporting small businesses through this type of investment. However, I believe that the recommended individual investment cap of $100 is unnecessarily low and a higher limit of $1000 will allow greater participation, especially from individuals closely connected to offerors who wish to show their support and involvement, while still limiting potential losses.
Such a rule might also impact "social lending" services such as LendingClub.com, which offers investments in personal loans, allowing currently-barred investors from states with restrictive securities laws to participate in such investments. While this varies somewhat from the purpose of the petition, I believe it would be a positive change as well.
Finally, I would like to note that the role and trustworthiness of the investing platform (e.g. Kickstarter, IndieGoGo) are important factors in the risk of the investment. For example, a platform which thoroughly vets potential offerors might significantly decrease the risk of fraud but also give the investor a reduced sense of risk in the investment. There is also the potential for the platform itself to defraud both investors and offerors. While these sorts of issues need not be insurmountable, they should be considered.
With appropriate care, I believe an exemption for small offerings could have a positive impact for investors, small businesses, and communities.
Thank you,
Ben Schwartz