September 8, 2011
I am writing to comment on File No. 4-605, Request for rulemaking to exempt securities offerings up to $100,000 with $100 maximum per investor from registration, submitted by the Sustainable Economies Law Center.
I have written an article, Crowdfunding and the Federal Securities Laws, that supports the general idea proposed in this rulemaking petition and suggests modifications and additions to the proposed rule. That article considers the possibility of a crowdfunding exemption in great detail. I would like to submit that article as my comment. It is available at http://ssrn.com/abstract=1916184.
C. Steven Bradford
Earl Dunlap Distinguished Professor
University of Nebraska-Lincoln
College of Law
P.O. Box 830902
Lincoln, NE 68583-0902