October 8, 2013
Please don't amend Reg D and Form D and make life more difficult for startups to raise money. This is contrary to what Congress intended in the JOBS Act. The whole point of the JOBS Act was to make it easier for startups to raise money, not harder.
We don't want new filing requirements. Congress didn't specify any in the JOBS Act. Or request that you add new filing requirements. Why are you?
We don't want penalties for late filings. There are none now. Congress never said in the JOBS Act to impose any. Why are you now?
We don't want to have to complete more paperwork to raise money. Requiring more information on Form D is also something that is specifically contrary to the intentions and spirit of the JOBS Act.
We don't want to have to file forms in advance of generally soliciting. Congress didn't specify this. Why are you?
It is already very difficult for startups to raise funds. Please don't harm us by making it even harder.
I specifically cite Mary Jo White. You continue to pander to Wall St., but it's QUITE CLEAR that it's Wall St. that commits the crimes of monstrous proportions. For example, why are you putting the onus (and penalties) on the start up and NOT the finder (or, previously, the promoter) under these proposed? Making a start up ineligible for general solicitation under Reg. C, when you had already taken on "friends and family" is just ludicrously stupid.
You have grossly perverted the spirit of the JOBS act by these injurious actions of yours.
(I am afraid to put my name and yet am making every effort to be compliant).