September 18, 2013
1) I strongly disagree that startups should have to notify the SEC 15 days before they publicly discuss raising money. This is an unreasonable bureaucratic requirement.
2) I strongly disagree that start-ups must file documents with the SEC every time they update their offering materials. Offering materials are updated frequently and this would be an unnecessary hardship.
3) I strongly disagree that start-ups must include legal boilerplate every time they talk about their financing publicly. This information can be adequately disseminated at the time the securities are documented.