Subject: File No. 4-605
From: Christine Kahm, MBA 2011
Affiliation: Presidio Graduate School

October 8, 2010

Here are my comments in regards to the petition for rulemaking change #4-605:

I am writing in support of this proposal. I believe that the rule change will galvanize the emerging community supported entrepreneurship movement. It will provide straightforward, accessible capital for growth and create main street jobs while offering the limits necessary for investor and entrepreneur protection.

Although the proposal discusses these assertions in more detail, I would like to stress that now is the time to facilitate crowdsourced funding for three reasons:

  1. The success of existing crowdsourced portals such as Kickstarter and Indiegogo have proven large public interest in this model. Regular individuals are looking to do something meaningful with their money. This would provide a new avenue for investment while preventing large-scale individual losses.
  2. Crowdsourced investing projects are by definition diversified. By seeking widespread support, projects receive useful feedback while simultaneously creating a potential customer base - in essence, taking steps to ensure success that are not necessary with other types of capital acquisition.
  3. Additional capital in the small business sector will lead to an increase in jobs - without tax cuts, additional government spending or lending programs.

I am an ardent believer that commerce and community building go hand in hand. This exemption will funnel much needed capital towards small businesses, providing positive benefits in local communities and beyond.

Christine Kahm, MBA 2011
Presidio Graduate School
San Francisco, CA