Oct. 12, 2026
Dear Ms. Countryman: On behalf of ICON Capital Group, LLC, I strongly support the petition to increase the Regulation Crowdfunding offering limit from $5 million to $20 million per 12-month period and automatically index that limit to inflation. We urge the Commission to prioritize this reform. ICON Capital Group, LLC is an SEC-registered Broker-Dealer and FINRA and SIPC member. We specialize in capital formation under the Jumpstart Our Business Startups Act of 2012, conducting offerings under Regulation Crowdfunding, Regulation D, and Regulation A. Our support reflects direct experience helping companies navigate these exemptions and the practical financing constraints imposed by the current Regulation Crowdfunding limit. For early-stage companies in biotechnology, healthcare, medical technology, and other capital-intensive industries, access to capital determines whether promising innovations advance or stall. Clinical studies, product development, regulatory submissions, and commercialization require substantial funding. In our experience, the $5 million ceiling can fall well short of the capital necessary to reach a meaningful business milestone. The consequences extend beyond issuers. When companies reach the limit, they must consider dividing their financing among multiple exemptions, undertaking additional offerings, or shifting to accredited-investor-only financing. These alternatives introduce additional expense and complexity and can exclude non-accredited investors who supported the company at its earliest stages. Investors should not lose the opportunity to continue supporting a company simply because its financing needs have outgrown an unnecessarily restrictive offering limit. Regulation Crowdfunding provides an important avenue for accredited and non-accredited investors to participate together within a framework of required disclosures, regulated intermediaries, and applicable investment limits. A $20 million ceiling would give issuers greater flexibility to structure a financing around their actual business needs. It could allow a company to fund a substantial development milestone through one offering, reduce duplicative costs, and devote more of its capital to operations and innovation. We strongly support retaining the existing investor protections as the offering limit increases. Required disclosures, financial statement requirements, intermediary oversight, applicable investor limits, and antifraud protections should remain central to the framework. A higher issuer offering limit need not entail weakening those safeguards. Automatic inflation indexing is also essential. Without it, the purchasing power of the revised limit will erode, gradually recreating the same financing constraints this petition seeks to address. We further support coordinated changes to Rule 12g-6 and related Exchange Act registration thresholds, consistent with investor protection and the Commission’s authority. Successful capital formation should not create a premature reporting burden that consumes the resources an early-stage company has just raised to grow its business. The Commission should move promptly to grant the requested relief through rulemaking, whether independently or as part of a broader exempt-offering initiative. Raising the limit to $20 million, indexing it to inflation, and adopting appropriate conforming relief would strengthen the JOBS Act’s promise: broader access to capital for American businesses and broader opportunities for investors to participate in their growth. ICON Capital Group strongly endorses this petition and urges the Commission to act. Respectfully, John Calicchio President/CEO ICON Capital Group, LLC MEMBER FINRA/SIPC John Calicchio – President/CEO 5 Upper Newport Plaza Suite 200 Newport Beach, CA 92660 888-324-ICON 949-418-8669 Direct 949-693-0900 FAX WWW.ICONCAPG.COM jc@iconcapg.com ICON Capital Group, LLC , member FINRA and SIPC THIS COMMUNICATION IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND CONTAINS OR MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this communication is not the intended recipient (or the employee or agent responsible for delivering to the intended recipient), you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please disregard and delete this communication. This communication should not be construed as an offer to buy or sell any security.