Subject: File No. S7-09-13
From: Charles E Williams, MBA, EA
Affiliation: Founder and Managing Director, Pioneer Realty Capital

January 15, 2014

First of all, I applaud the efforts of the Federal Government to make capital available for small business owners who traditionally do not have access to capital. However, I do have a concern:

Limiting the amount of capital that a firm can raise to $1 Million in one year severely limit many industries from participating. These industries generally require large upfront investments but also tend to stabilize very quickly. These industries include Manufacturing, Oil Gas, and Real Estate to name a few.

Please consider increasing the $1 Million one year limit to at least $5 Million.

Thank you in advance for your favorable consideration.


Charles Williams, MBA, EA
Pioneer Realty Capital