Subject: SEC Regulatory Initiatives Under the JOBS Act: Title II Access to Capital for Job Creators
From: Len Bland, CPA
Affiliation: CEO, Concept Equity Group

September 17, 2012

The JOBS Act promises to begin solving a problem for entrepreneurs that want to raise capital and are not professional fund raisers. There is currently no good alternative for entrepreneurs that can create jobs.

  1. Banks are under greater regulation and capital requirements. They won't lend to startups and early stage companies.
  2. Brokers are under increased scrutiny including requirements to put every deal through their risk management department. Small raises of less than $5MM don't deliver enough return to the brokerage for the effort.
  3. Investment Banks face FINRA regulations that eliminate their interest in smaller raises.
  4. The SEC has drawn the rules regarding unregulated finders ever tighter, eliminating their ability to help.

Please implement simple regulations to support the JOBS Act and allow general solicitation over the Internet to investors.


Len Bland, CPA