Subject: File No. 4-605
From: Michael F. Meara, CFP

March 18, 2011

These are comments in regards to a petition for rulemaking change.

As a serial entrepreneur, investor, investment advisor and non-profit board leader I have worked with small businesses for over 25 years and witnessed the constraints placed on small businesses ability to grow, prosper and add value to their communities because of antiquated securities regulation. Any student of history and the economy knows that small businesses are huge job creators and are a major source of wealth creation and economic development. Making it easier for small business to raise capital and for local investors to own a part of these companies just makes sense.

I would argue that the exemption requested does not go far enough and the maximum should be more like $500,000. Please authorize this simple exemption to move things in the right direction and help the biggest job creation engine in this country to get a little more fuel.

Michael F. Meara, CFP
CEO-Pacific Mountain Advisors, Inc.
Chairman of the board-Santa Cruz Community Credit Union
Treasurer-Santa Cruz County Community Foundation