Subject: File No. S7-09-13
From: Aaron McDaniel
Affiliation: CEO, Tycoon Real Estate Corporation

September 23, 2014

SEC JOBS Act Title III Implementation Team,

I am a start-up founder who is excited about the potential opportunities that implementation of Title III of the JOBS Act will create.

My company, Tycoon Real Estate, group-funds real estate deals brought to our platform by experienced developers with marquis properties. Currently we limit our offerings to accredited investors. Real estate investing is expensive, often costing tens, if not hundreds of thousands of dollars to invest. Through Tycoon's platform, investors can diversify their real estate investment portfolio to mitigate risk for much less than it would cost to invest on their own (Tycoon investments can be as low as $1000).

For many years, the everyday American has been restricted from accessing many of the best wealth-building private deals. While it is important to have clear rules to protect non-accredited investors, the current rules and lack of implementation of Title III to date has blocked nearly 240 Million Americans from the freedom to invest in the way that only the super-wealthy currently can. 

We intend to participate in crowdfunding campaigns under the proposed Title III rules and are excited for these rules to be implemented by your agency.

While there are many complexities and considerations for successful implementation of Title III rules, we recognize that it has been more than 30 months since the JOBS Act was signed into law without an implementation of Title III. 

That said, we encourage your agency to issue the final Title III rules ASAP so that Tycoon and other companies in the space can engage in equity crowdfunding and offer more Americans the ability to access the most proven way to consistently build wealth over generations; real estate investing. 

Thank you,

Aaron McDaniel

CEO, Tycoon Real Estate Corporation