July 11, 2012
Here are my suggestions to reduce costs and market frictions:
- Although audited or reviewed financial statements are required when raising over $100K, please consider allowing these financial statements to be tax basis (OCBOA, not GAAP basis).
- If or when tax returns must be disclosed, please allow the reasonable redaction of TINs and other confidential matters.
- Please do not require PCAOB registration by an auditor/reviewer of crowdfunding financial statements.
Please find ways to encourage centralization of investor relations and equity transaction functions (eg by a centralized investor relations or brokerage firm, or even at the portal). I believe that shareholder correspondence, tracking equity, accounting for transactions and other special situations (shareholder divorce, bankruptcy, probate, escheat etc.) would be a significant ongoing burden and a compliance risk for a small business having 1000+ shareholders and multiple classes of equity/debt.
I want to briefly echo comments by others that crowdfunding should not preclude other approaches (funding by accredited investors or by foreigners).
Thanks for your consideration of my comments
Steve Rabin MBA CPA CVA