September 15, 2014
Re: File Number S7-09-13
To The Honorable Mary Jo White, Commissioner Luis A. Aguilar, Commissioner Daniel M. Gallagher, Commissioner Kara M. Stein, Commissioner Michael S. Piwowar, and Title III Team (Sebastian Gomez Abero, Jessica Dickerson, Division of Corporation Finance, and Joseph Furey, Joanna Rutkawski, Leila Bham, Timothy White and Carla Carriveau, Division of Trading and Markets):
Thank you in advance for acceptance of this late commentary submission on the proposed rules. I recognize the tremendous effort expended thus far in the development and drafting of the complex rules required to implement Title III of the JOBS Act and your efforts to protect small investors.
An entire industry is waiting to be launched and hundreds of thousands of new jobs will be created consistent with the legislative intent behind the JOBS Act as soon as the rules are finalized. This was the point and will be the effect of the JPBS Act once these rules are realized.
There seems to be resistance from the extant private equity industry to these changes and I continually see irrelevant if not deceptive statements relating to the efficacy of the rules as currently proposed.
Yes, there will be things to work through, processes which will need improvements, and rule adjustments but I have every confidence the SEC will be able to navigate these issues as they arise. The current proposed rules are workable.
For the reasons articulated above, I urge you to move forward with the vote to publish the final rules.
Respectfully,
Ronald A. Newcomb