Subject: File No. S7-09-13
From: Earl Brown
Affiliation: CEO, JumperCard

August 27, 2014

8.27.14

   re:  file is number S7-09-13.

  Sirs,

a) Your Title III platform can operate under the rules as proposed
b) Costs to issuers are much lower than stated in the proposed rules
c) While we would like to see some changes in the future, the proposed rules are workable
d) We intend to launch your platform to facilitate Title III crowdfunding

  We’ve been waiting a long time to get these regs in place - it’s time they are implemented.

Earl Brown, CEO
JUMPER CARD
[email address redacted]
[phone number redacted]
www.jumpercard.com
www.capitalizedfunding.com