Oct. 12, 2026
Vanessa A. Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Re: File No. 4-914, Petition for Rulemaking to Amend the Regulation Crowdfunding Offering Limit Dear Ms. Countryman: We write in support of the petition in File No. 4-914 asking the Commission to raise the Regulation Crowdfunding offering limit from $5 million to $20 million per 12-month period and index it to inflation. MedTech Syndicates brings clinician investors together with early-stage medical technology companies. We work with offerings conducted under Regulation Crowdfunding, Regulation D, and Regulation A, so we see how the current limit shapes issuer behavior across all three. Medical technology is capital-intensive. Taking a device from prototype through design verification, clinical evidence, and regulatory clearance routinely requires more than $5 million. For companies like these, the current limit does not contain the raise; it fragments it. Issuers split their financing across parallel exemptions or move to accredited-only offerings. When that happens, the clinicians best positioned to evaluate these products, including nurses, technicians, therapists, and early-career physicians who are not accredited investors, lose the ability to participate in the companies they helped validate. Regulation Crowdfunding is a channel that lets them invest alongside Reg D investors, with full disclosure, investment limits, and a regulated intermediary. As the companies in our network move from early feasibility work into pivotal trials and regulatory submissions, we expect their capital needs to exceed the current limit with increasing frequency. Under today’s rule, those companies will face the same choice: fragment the round or exclude the non-accredited clinicians who supported them early. A $20 million limit, indexed to inflation, would let capital-intensive companies complete a real financing in a single, fully disclosed offering while leaving every investor protection in place. We also support conforming the related Exchange Act thresholds, including the Rule 12g-6 total asset condition, so that a successful raise does not force an early-stage company into full reporting. We urge the Commission to grant the petition, or to include this relief in its anticipated exempt offering rulemaking. Respectfully, Mark Stevenson COO MedTech Syndicates