Subject: File No. JOBS Act Title III
From: Kelly A Maurer
Affiliation: Treasurer, Buffalo First Member, Buffalo Common Wealth LLC Assistant Treasurer, Buffalo Cooperative FCU

April 16, 2012

This is a good step forward - the general public has access to much more information than it had 100 years ago and the general education level is much higher. The idea that millionaires somehow have the savvy to invest and that folks of more modest means do not is outdated and often incorrect.

Creating an intermediary who can bring small time investors together with small community businesses is one way to approach this when it come to business lending.

For direct equity investing, however, it may be best to create a basic set of guidelines that micro-enterprises can use to create their equity offerings.

Clarity, simplicity, and transparency are important. If the regulations, and the language for offerings under the regulations, is too dense the resulting obfuscation will only serve to confuse both investor and the businesses the resulting reliance on expensive attorneys will make the crowdfunding idea ineffecive.