October 29, 2013
Although the proposed rule is a long over-due step in the right direction, the following changes should be made to the rule to reduce and / or remove the barriers to raising capital:
1. Maximum amount is too low. (Increase to $5 to $10 million.)
2. Restrictions too onerous, numerous, and restrictive. (Contradicts intended purpose of crowdfunding legislation.)
3. Use of intermediaries unnecessary, too cumbersome, and costly. (Reduces amount of capital received because of commissions paid for intermediary services.)
4. Use of accounting firms unnecessary, cumbersome, and costly. (Not applicable for start-ups because there are no financial statements to audit, only financial forecasts / plans. Reduces amount of capital received because of fees paid for accounting services.)
5. Very apparent the self-interests of legal, accounting, and investment firms (under the veil of protecting the public) were incorporated into proposed rule. (Equal input from public and those companies raising capital should also be incorporated into rule.)