Subject: File No. S7-06-13
From: Spencer P Abbs
Affiliation: Start-up Development and Funding, MidMichigan Innovation Center and BlueWater Angels

August 15, 2013

What this legislation is attempting to accomplish is actually a fallacy with great consequences. The current analysis of accredited investors is sufficient for investment in start ups. With the proposed legislation requiring validation every 90 days, it presents the inevitable situation where angel investors are simply going to stop investing shifting the paradigm of investment to Wall Street. Start ups do not have the time, resources, or possibly the skill to verify whether an investor is accredited or not. Who says the entrepreneur is well-rounded when required to audit the financials of their investors? The JOBS act hinders investment in start ups and punishes these willing entrepreneurs for raising money incorrectly.