August 16, 2013
The 1 year penalty box requirement is not the right strategy for penalizing start ups who break the rules accidentally. Willful violations should be penalized, but obviously the difficulty in determining a willful violation versus an accidental will be difficult. I would suggest that for start ups that break the rules, more stringent requirements should be set forth for a second round of filing. The increased burden should force the start up to get the process correct and become as transparent as possible with no time penalty except the speed at which they can meet an increased level of requirements and demonstrate they're not in willful violation.
Thanks for your time.