Subject: File No. JOBS Act Title III
From: Harry Shamir
Affiliation: Principal, RDA Co

April 16, 2012

Comments attached.

The attached proposes that the microfunds invested by the population at large, be invested into State initiated investment corporations, of which the small investments would purchase equity. The objective is to gain from the efficiency of private enterprise management of the investment corporations, but have State oversight ensuring that the investments follow public interests, even when the latter are long term as opposed to the short term preferred by strictly business approaches.

The combination of public and private activity is also designed to enable gaining access to publicly owned facilities as well as private, and making optimal uses of public funded services such as available through the SBA and its grantees.

The attached was written with Massachusetts in mind, but is applicable to all States.