We strongly urge the SEC to issue clarifications which support the intent of Title IV to provide added options for capital formation to smaller firms. We are aware of many mature companies that have established proven business models and who have growing revenues, satisfied customers, and profits – but who currently lack options to raise expansion capital that is needed to fund their ongoing growth.

Many studies on job creation underscore that companies are spurred to significant added job creation post an IPO (see http://www.kauffman.org/uploadedfiles/post_ipo_report.pdf).  We believe that the enhancements of Regulation A contemplated in Title IV could spark a wave of mini IPOs that would lead to significant growth in our economy at a time when private sector job creation is most sorely needed.

With election behind us, there is no time like the present to complete the needed work on Regulation A and create viable options for smaller firms to raise growth capital.


Paul Getty
Managing Director

777 North First Street, 7th Floor
San Jose, CA 95112