Subject: File No. S7-09-13
From: David Johnson
Affiliation: tempCFO, Inc.

August 26, 2014

To Whom It May Concern:

TempCFO, founded in 1999, outsources the accounting and finance functions for small businesses.  Our platform and team approach allow small businesses to have a full functioning accounting department at a faction of the cost.   

After reviewing the proposed rules for Title III of the JOBS Act, I firmly believe that TempCFO can offer a solution for entrepreneurs looking to raise funds on these portals. Our services include a team and platform that is used on an as-needed basis.  By leveraging our infrastructure and experience, entrepreneurs can have a full-functioning accounting department often at savings of 50% or more compared to creating and maintaining an in house solution.  We can assist entrepreneurs with complex financial transactions, insight to maximize financial opportunities and tax compliance.  Ultimately, our platform allows the founding team to focus on developing their product, exceed milestones and increase valuation, while growing and creating job opportunities. 

TempCFO can produce timely and accurate financial reporting for small businesses.  In addition, we can assist them in meeting any additional financial information required or needed to be compliant from the application stage and ongoing.

In the past 15 years, TempCFO has worked with over 3,000 startup companies. Title III will allow these companies to grow, acquire new customers and create jobs. Title III would be a catalyst for new company formation. 

It would be ideal for many of the companies that we work with to begin crowdfunding as soon as possible in order to hire new employees and expand operations. We have reached out to several Title III crowdfunding portals and are ready to work as a resource and a solution for entrepreneurs looking to raise capital on their platforms.

I urge you to issue the final rules as soon as possible so that we can begin helping these companies raise capital. Title III will benefit not just our business, but scores of businesses nationwide and help the economy grow.  I’d be happy to work with your staff in any helpful capacity.

 

Sincerely,

 

David Johnson
Chief Executive Officer
tempCFO, Inc.