Subject: File No. JOBS Act Title III

June 10, 2012

Among other things, the JOBS Act imposes several restrictions on the activities of a registered funding portal. Given a funding portal's prohibition from engaging in the items below, what fees are allowable for the funding portal's efforts?

provide investment advice or make recommendations

solicit purchases, sales, or offers to buy the securities offered or displayed on its website or portal

compensate employees, agents, or other persons for such solicitation or based on the sale of securities displayed or referenced on its website or portal

hold, manage, possess, or otherwise handle investor funds or securities or

engage in any other activities the SEC determines to prohibit in its crowdfunding rulemaking.
In addition, each funding portal and each crowdfunding broker is prohibited from:

compensating promoters, finders, or lead generators for providing the intermediary with the personal identifying information of any potential investor or

allowing its directors, officers, or partners (or any person occupying a similar status or performing a similar function) to have a financial interest in any issuer using the services of the intermediary.