From: Karl M Sjogren
Sent: Thursday, April 25, 2013 2:28 PM
Subject: A Call to the SEC to Require Valuation Disclosure

Dear Chairman White,
As you consider how to lead the agency’s implementation of the JOBS Act, I ask that you consider a requirement that any issuer of equity securities (via a Reg. D, Reg. A, S1, etc.);  

  1. disclose the valuation it has given itself given the terms of the offering, and,
  2. discuss the factors it considered when setting its valuation. 

I believe it would significantly expand the number of valuation-aware investors, and, encourage issuers to compete for investors by offering better terms.  In short, it would encourage market forces to enhance investor protections and responsibly expand small company access to capital.  

The attached article lays out my case for a valuation disclosure requirement.  It is also available online here

Thank you for considering it, and, best wishes to you as you tackle your new responsibilities.

Karl M Sjogren