Subject: File No. JOBS Act Title III
From: David E Simpson, CFA
Affiliation: Dex Offshore Entertainment LLC

April 16, 2012

If a Platform maintains an ongoing role in an issuer, vis a vis, monitoring and reporting performance to shareholders, helping with development and implementation of strategy, facilitating financing from additional sources -- could the CF Portal charge for those services in the forms of equity in the company?

So, your agnostic portal is an exchange place and they just connect investors and entrepreneurs and have no further interest in the affairs of the company. I would argue that my portal's business model is more like a VC or Private Equit model where the investors are also paying for the investment opportunities to be screened up front and monitored going on - ultimately leading to a profitable exit. I'm arguing that this should be a permitted model, so long as the fees are transparent.

I have another issue - the credit card and banking industries will make more just passing electronic money around than the people in the CF industry. They're going to charge $.30 + 3% per transaction and then hit the investor with higher rates on their credit cards saying it was a cash advance. There has to be a better way. That's totally unfair to the consumer and undermines the flow of capital. Maybe you can force Paypal to only charge the transaction fee if the funds are coming out of a cash balance in a checking account?