Subject: File No. JOBS Act Title I
From: Guy Lohman, PhD
Affiliation: IBM Research -- Almaden

June 29, 2012

I speak as an individual investor, and NOT on behalf of IBM. Nor am I an expert in finance I'm a computer scientist.

I am concerned that the JOBS Act reduces oversight by the SEC to an almost non-existant level. While I like the escape valve that "crowd-funding" provides, allowing a start-up to secure funding from sources other than the usual VCs, investment banks, etc., I worry that the lack of any oversight by the SEC will provide a huge opportunity for abuse by speculators and shadow companies, at the expense of the small investor. Without transparency into the inner-workings of the company, as currently required for major companies, these start-ups will be free to pump up their stock with hype, benefitting insiders at the expense of those duped into investing with only half the story. The experience of the 2008 Great Recession should have reminded us that more oversight, not less, is needed, for companies both "too big to fail" and "too small to be funded". I'm all for breaking the stranglehold that large investment banks and VCs have on getting funds, but let's do it in a way that assures that investors are aware of the risks, not kept in the dark until it's too late.