Subject: File No. 4-606
From: Odded Beraha
Affiliation: entrepreneur

August 4, 2010

I have been a member of TiE-Boston for many years. TiE is an organization that supports entrepreneurs through education and networking. The organization's break down is primarily executives of companies, would be entrepreneurs and start-ups and academia.

10 years ago, a start-up could approach any of the VCs in the organization about funding and be given advice as to what is needed and be invested in. Today, VCs are no longer approachable at the early stages and folks who need funding find that even Angel Investors won't invest unless the would be entrepreneurs are far further down the street than had been.

Entrepreneurs are now asking small strategic advisors for help in preparing for Institutional Investors. This means everything from writing a business plan to preparing an Investment presentation to introductions to investors. These very same entrepreneurs are only offering payment for these services based on success.

This situation requires the advisor to tie their payment directly or indirectly to their ability to raise funds. This is not the established fund manager and from everything I see against SEC regulations. And Yet... The entrepreneur seemingly does not have a choice if they want funding. Some have taken their efforts outside the country to obtain the funds and yet, given the funds are received in the US, are still on questionable legal grounds.

I want to see clear rules for situations such as this for folks in SBANE, SCORE and other such organizations that wish to support the entrepreneurs to help and make it possible for would be start-ups to get what it takes to get going legally.