Subject: File No. S7-06-13
From: Jason A Crawford
Affiliation: Former co-founder CTO, Kima Labs, Inc.

July 17, 2013

I'm afraid that this proposal undermines the very intent of the JOBS act. There have been many good analyses, but this one is particularly worrying:

"... angels will no longer be able to self-certify their accredited status. Instead issuers will need to verify accredited status with safe harbor categories such as providing the issuer a copy of your W-2, tax filing, or brokerage statement or a third-party (attorney, accountant, or registered investment advisor) certifies that you are accredited....

"I don't know about you, but there is NO WAY I am going to give an entrepreneur any of these documents. Every angel I've talked with about the rules feels the same way....

"These requirements could kill angel investment."

I urge you to reject the extra, onerous requirements this proposal places on companies trying to raise money (especially startups trying to raise angel rounds).