Subject: File# S7-05-20 Comments
From: T.W. Kennedy
Affiliation: Regulated Funding Portal Industry Association

Mar. 6, 2020


To:  Securities and Exchange Commission 
       Washington, D.C. 

 REF:  Comments to Rule Making for File# S7-05-20 
           Facilitating Capital Formation and Expanding 

           Investment Opportunities by Improving Access 

           to Capital in Private Markets. 

                                                                March. 6th. 2020 

We thank SEC and Chairman Clyton to considering  

to increase the maximum allowed funding from 

$1,070,000 to $ 5 Million, and to reversing the 

"whichever is lesser" to back as Congress originally 

intended in HR3606 Title III to, "whichever is more", 

regarding yearly income v/s networth. 

However we still advocating to increase the maximum 

allowed "crowdfunded stockholders" from the current 

500 to 2,500, to make Regulation Crowdfunding really 

For example, during the first full year of operation of 

Regulation Crowdfunding, one of the most successful 

portal (intermediary) had over 102,000 investor members. 

(investors must stay with the same portal for a full year, 

according to regulations). However, the average member 

contributed only $400.oo USD for the whole year. NOT 

very much!   (we understand, the following years that 

average improved somewhat) 

If we do the math, $400 X 500 only adds up to $200,000 USD, 
a long way even to the current $1,070,000, maximum allowed, 

much-less to do a second offering a year later as the Act 

permits it.  We realize that with Accredited investors being 

allowed unrestricted investment,  will much improve 
the chances to reach the maximum allowed under 

Regulation Crowdfunding, but with the proposed increase, 

once again, we will run out of "crowdfunded stockholders" 
before the campaign reaches that $5 Million USD cap. 

We appreciate if the Commission would include that important 

change as well. 
Respectfully submitted by, 
T.W. Kennedy, BE 
Regulated Funding Portal Industry Association 
Long Beach, California