May 7, 2013
Excerpts follow from my attached article
A Call to the SEC to Require Valuation Disclosure
No matter how the JOBS Act is implemented, I have a suggestion for how to protect investors that could also help companies compete for capital require that all companies disclose the valuation that they give themselves when they offer stock.
Two negative consequences result from the present lack of a disclosure requirement. Unsophisticated investors (including accredited ones) are more likely invest unwisely, and, issuers are less likely to compete for investors by offering better terms.
Valuation disclosure may sound esoteric, but it's not. The SEC requires issuers to disclose risk factors in offering documents. Sometimes, the result is pages of eye-glazing prose.
A requirement for valuation disclosure could be accomplished on one page and it would do more, I suspect, to protect investors.
It would also enhance competition in the equity capital market-whether crowdfunded or not.(Attached File #1: jobstitleii-90.pdf)