September 12, 2013
Please find my comments below.
In short I do not support these proposed amendments.
I run, LeaseQ, Inc. an Angel funded startup. I believe that these efforts in general will: a) only make starting a company even more difficult, b) will turn a vast network of people currently involved in a largely informal process in to cheats as thousands of discussions and presentations will certainly be made prior to formal execution of the proposed rules, and c) I doubt that these new rules will thwart any conscious criminal activities happening today... even if the SEC is going to add significant resources to vet every new start up.