Subject: SEC Regulatory Initiatives Under the JOBS Act: Title III Crowdfunding
From: Christine Landon

July 18, 2012

I am wondering how gifts will be accounted for in the limits set under crowdfunding (Title III). For example, if someone wants to give a gift of $500 to a college graduate, a normal practice, and did so in an trackable way (like a tracked crowdfundgiftcard) wouldn't the recepient be able to add this amount onto their investment cap total, as it is a gift (non taxable) and therefore not income? Additionally, what about credits earned on a credit card (like frequent flyer miles). I know this is getting a bit into the weeds, but they are important questions, especially since the total non-taxable gift amount is $10,000. Thank you for your time.