Subject: File No. JOBS Act Title I
From: Albert Rogat

June 29, 2012

I am a concerned investor who has serious reservations about the JOBS Act of 2012.

The SEC needs to protect individual investors against any unintended consequences of the JOBS Act by offering a robust response to its worst parts.

The Act allows transforming crowdfunding into a bona fide capital market which is full of perils. The opportunities for misuse and abuse are enormous due to the inherently speculative nature of crowdfunding businesses and weaker accounting scrutiny and corporate governance.

This Act exempts a wide swath of companies from key oversight measures for up to five years after coming public. Known as small "emerging growth companies," the definition includes any operation with less than $1 billion in annual revenue and $700 million (or less) in public float. I'd see an operation with annual revenue below $500M as an emerging growth company, not $1B.

This definition of "small" encompasses the vast majority of companies coming public. For instance, of the 79 IPOs this year, a full 69 of them qualified for emerging growth company treatment. That's absurd...