Subject: File No. JOBS Act Title IV
From: Brad Jacobsen
Affiliation: Vantus Law Group, P.C.

October 5, 2012

We have a number of clients eager to begin to use the JOBS Act to more easily access capital from accredited investors through general solicitations. We ask that the SEC provide safe harbors/advise on the precautions a company should take to ensure that investors are "accredited investors" under the JOBS Act.

Additionally, a number of potential clients would like to offer services through a website to either pre-qualify accredited investors or provide a location that accredited investors can review available investments. To what can third parties participate and be compensated in JOBS Act accredited only investor offerings without being deemed a broker/dealer or underwriter.

Thank you.