September 15, 2010
There follows my comments in regards to the petition for rulemaking change #4-605:
Last year a colleague and I were inspired by the business model of Kiva.com to research the possibility of using "crowdfunding" to support socially-beneficial businesses around the world. The basic idea was that we could aggregate small investments from many people into a solid equity investment in a sustainable, small and growing business in the developing world. Many of these businesses are not served by current capital structures, and we believed that their needs matched well with the desires of many American professionals who had some disposable income and a desire to connect with and support others around the world who were creating economic, social, and environmental value. We wanted this to be in an equitable, dignified manner, and thus we sought to create investment structures, not donations.
Unfortunately, given the restrictive nature of the current SEC regulatory environment we realized that this would be extremely difficult, if not impossible. From my research I know that I'm not the only one who has run into this issue. While I understand the logic of the regulatory system, especially when applied to large individual investments, the power of the internet to aggregate small sums of money can significantly limit individual risk while still enabling larger impact, and thus I strongly support this rulemaking change to bring our regulatory environment in line with the realities of modern technology and financial behavior.