Subject: File No. JOBS Act Title III
From: Thomas O Markel, Jr.

April 26, 2012

The Crowdfund Act is desperately needed in todays non-lending small business environment for several reasons:
1) Banks have not re-entered the business of lending to small businesses.
2) Even if they were back in the land scape of lending they would only lend to the business owner who meets the 5 C's of credit without a blemish on any of the 5 C's - only 33% of all small businesses fall into these 5 C's leaving 66% seeking other ways of accessing capital.
3) the general public needs marketplaces of investing opportunities in start-ups and growing small businesses in order to have a chance to win big. Look at how much is spent in the lottery business. An investment in a business has arguably more upside than winning the lottery.
4) the excitement shared by both the business and the investor through online forums, blogs, and social media sites will help drive more business to the business for a greater chance of success than the marketing strategies of yesteryear.
5) the advent of social media sites will make business owners more concerned about how they perform the who, what, where, when and why of their business or else the bad news like a forest fire will shut them down quickly.
6) the pensions, 401k's, etc are great opportunities to power America's job marketplace - the small business. The retirement funds are long term and with reasonable diversity risk can make a big difference 20-30 years from now on the Social Security burden if a big hit is earned from a small investment.
7) the small business owner although a consumer do not spend like a consumer. Given small funds, they spend to drive more business, buy equipment, hire people, advertise, travel etc which are called for today to turn this economy around.
8) if the 25 million small businesses each hired 1 person we would have no unemployment problems. Giving small business access to low cost, hassle free ways to access capital insures more jobs.
9) their will be abuse not by the greed or stupidity of investors or small business issuers trying to get rich or fail, but from popup newby website promoters taking peoples money. Steps can be taken to reduce this risk and it is not licensing or heavy handed govt. oversight. The social media sites are the great equalizer of who is or who is not serving the people, along with website partners who are seeking a life long commitment to helping small business.
10) small businesses need hope today and asap. They need to hire, they need to advertise, they need equipment, they need to travel, the need encouragement, they need to share best practices and ideas, learn better ways of managing finances, prepare SMART business strategies, become virtuous leaders and meet influential professional who help grow their business. By having businesses prepare a business plan by a 3rd party, by having the business prepare its books by a 3rd party, by having the business manage its credit and the credit it grants to others managed by a 3rd party, by having a business report its financials in transparent ways monthly, by having a business buy life insurance and other insurance in short by having a business use the skills and talents of a virtual CFO will ensure greater success and get America growing again.