July 23, 2013
As an attorney that regularly works with startup companies raising capital, I am deeply disappointed in the proposed rules concerning general solicitation. Specifically, the additional compliance requirements (e.g. legends, potential 1 year penalty, and new Form D requirements) are so burdensome that my clients will continue to view general solicitation as an non-option.
Furthermore, it seems to me that in these accredited-investor-only offerings, the additional requirements provide very little in the way of additional protections to the public.
The intent of the JOBS Act was to increase access to capital. Please don't squander one of the few bipartisan actions of the last few years by adopting general solicitation rules that neuter the Act of its intended benefits to business startups.