August 27, 2013
1.Please dont issue these rules at all. Congress didnt ask you to issue these rules. In fact, rules that Congress did ask you to issue you still havent gotten around to (crowdfunding rules, for example).
2.The 15-day Advance Form D filing requirement is unnecessary and a bad idea.
3.The one-year death penalty box is a terrible idea.
4.The filing of the Form D should not be due until after money is raised.
5.The SEC ought to consider lengthening the time period to file the Form D to 30 or even 60 days after accepting funds.
6.Clarify the way demo days can be run, the way business plan competitions can work, and the way current fundraising platforms that keep information behind walled gardens for accredited investors only, do not constitute general solicitation. No founder, startup or demo day organizer or accelerator should have to guess on this key question under the law.