September 18, 2013
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
Subject: Request for Public Comments on SEC Regulatory Initiatives under the JOBS Act Relating to Section 12(g) of the Securities Exchange Act of 1934, as amended by JOBS Act Title V- Private Company Flexibility and Growth, Title VI - Capital Expansion, and Title Ill - Crowdfunding
To Whom It may Concern,
As a company who helps nonprofits unlock their assets in partnering with the investment community the regulations as described still layout a complex set of terms to comply or attempt to comply with under various situations. Many of the nonprofits who enter into ventures that we have created in these partnerships are use to government compliance to be licensed for the services they provide. However, the financial requirements as set out do not allow a simple application process that allows a person or entity to know if they really did comply.
I strongly urge the SEC to devise a form that is clear and has instructions that are short and to the point. These ventures would like to access the crowd funding opportunity as a source to create housing and businesses with a social entrepreneur direction. We ask that the process not be so complex that it requires the venture to pay entities or firms to conduct the process and receive a fee. This only reduces the impact of the funds being solicited.
I wish to make one other point. The Maddof fraud should highlight that a large number of the requirements being promoted by others implies that only firms certified by the SEC can best protect the interests of small investors. The billions lost was the result of many of these same individuals and entities not protecting the interests of their investor. Therefore, I disagree with the fact that an SEC approved individual or firm is best suited to protect the investor.
Therefore, it is really about disclosure and whether any entity follows up on the disclosed information being verified. By having the form submitted electronically the SEC will be able to program its computers for the capturing of information in a time sensitive period to better serve the public and to send out requests electronically when additional information is required or a correction is required.
Sincerely yours
Robert C. Guinto Jr., President