J. Howison Schroeder Chief Executive Officer Neuro-Innovators, Inc. 804 Persimmon Road Sewickley, PA 15143 June 30, 2026 Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: File Number DSP-3 — Comments on the SEC Draft Strategic Plan for Fiscal Years 2026–2030 Dear Secretary Countryman: I am writing in response to the Securities and Exchange Commission's Draft Strategic Plan for Fiscal Years 2026-2030. I appreciate the Commission’s stated focus on innovation, capital formation, investor protection, and regulatory modernization. I submit this comment as a serial life sciences entrepreneur, a former banker at JPMorgan, and an economist by training. I currently serve as CEO of Neuro-Innovators, Inc., a first-in-class clinical-stage drug development company pursuing combination therapies to enhance neuroplasticity - the brain’s capacity to repair and rebuild itself. The life sciences sector represents a unique category of startup. Our development timelines are long, driven by both the underlying science and the regulatory approval process, and we are frequently unable to generate revenue until after the substantial majority of development - and development expense - has already occurred. This combination of high risk and long lead time makes life sciences companies uniquely dependent on access to large amounts of patient, upfront risk capital. At the same time, our work is enormously consequential: it touches the lives of hundreds of millions of patients and survivors in the United States and around the world. Veteran life sciences dealmakers, with decades of tenure in the field, describe the last five years as the most difficult capital-raising environment in over forty years. Venture capital firms have grown larger, increasingly compensated through management fees rather than carried interest on successful outcomes, which has shifted their risk tolerance away from the earliest and highest-risk stages of company formation. Public markets, meanwhile, no longer function as a venue to raise development capital for early-stage companies; they have become primarily a liquidity mechanism for existing private investors. The result is threefold: the life sciences sector needs more efficient access to capital; the smaller private investor needs a genuine opportunity to participate in the upside that early-stage innovation can generate; and capital, broadly, needs to be free to flow toward promising ideas. This is part of what makes the United States exceptional. I have spoken with multiple immigrant entrepreneurs - including, memorably, several rideshare drivers - who uprooted their lives specifically because America remains a place where an individual can pursue an idea and build something that did not exist before. Capital formation policy is not an abstraction; it is the mechanism by which that promise is kept. Specific Recommendation: Modernizing Regulation Crowdfunding (Reg CF) Within the broader goal of expanding efficient, broad-based access to capital, I respectfully urge the Commission to use this strategic planning cycle to substantially modernize Regulation Crowdfunding. Reg CF was a meaningful step toward democratizing access to early-stage investment, but its current structure was not designed with capital-intensive, long-horizon sectors like biotechnology and life sciences in mind. I propose three specific changes: 1. Raise the Reg CF offering limit to $20 million annually. The current annual offering cap is several orders of magnitude below what a clinical-stage life sciences company needs to fund even a single Phase 2 study, let alone progress through later-stage trials. A $20 million annual ceiling would allow Reg CF to serve as a meaningful, complementary capital source alongside institutional venture financing for capital-intensive sectors, rather than remaining largely irrelevant to companies like ours. 2. Streamline and modernize Reg CF's disclosure, reporting, and intermediary rules. The compliance burden associated with Reg CF offerings - particularly ongoing reporting requirements and funding-portal intermediation rules - was calibrated for simple consumer or technology offerings, not for companies navigating concurrent FDA regulatory milestones. The Commission should consider a tailored disclosure framework for clinical-stage life sciences issuers that aligns Reg CF reporting obligations with material clinical and regulatory events, reducing duplicative or boilerplate filings while preserving meaningful investor protection. 3. Clarify that Reg CF investors are eligible for Internal Revenue Code Section 1202 qualified small business stock treatment. Section 1202 provides a significant capital gains exclusion for investors in qualified small business stock held longer than three to five years, and is one of the few federal incentives specifically designed to reward long-horizon risk capital of exactly the kind life sciences companies require. Many smaller investors participating through Reg CF portals are presently uncertain whether their holdings qualify, given ambiguity in how crowdfunding-issued securities are treated under Section 1202's requirements. I urge the Commission to coordinate with the Department of the Treasury and the Internal Revenue Service to issue clear, affirmative guidance confirming that properly structured Reg CF investments in qualifying small businesses are eligible for Section 1202 treatment. Clarity on this point would materially increase the attractiveness of Reg CF as a vehicle for retail participation in long-duration, high-impact sectors such as biotechnology. Taken together, these three changes - a higher offering ceiling, modernized and proportionate compliance obligations, and tax certainty for participating investors - would transform Reg CF from a mechanism principally suited to early consumer and technology ventures into a genuine complementary capital source for life sciences innovation, while extending the opportunity to participate in that innovation’s upside to a broader population of American investors. Thank you for the opportunity to comment, and for the Commission’s consideration of the unique capital formation challenges facing biotechnology and other life sciences companies as it finalizes its strategic priorities for the next five years. Respectfully submitted, J. Howison Schroeder Chief Executive Officer, Neuro-Innovators, Inc. Founding Member, BLPN Neuro-Innovators, Inc. https://neuro-innovators.com/