Subject: S7-05-20
From: Peter Farmer

Mar. 30, 2020


Dear Sirs,

I write regarding the rules for Regulation Crowdfunding. 

As a business that has made numerous investments in regulation crowdfunding in several jurisdictions, we are very supportive of proposed release 33-10763.

However, the economic situation is rapidly changing for the worse as a result of COVID-19. Small businesses are likely to be the ones that suffer the most and need access to capital to weather the storm. 

I note that some central banks are starting asset purchases to increase market liquidity – this is only meaningful if there is a way for such an action to cascade through the entire economy. Regulation Crowdfunding is one mechanism which could support that, but $1.07M is too low to be meaningful – it is too low at the best of times, has effectively reduced in real terms due to inflation since it was set and is certainly too low in the current circumstances. 

We would like the SEC to consider immediately raising the limit (we consider that $5M is appropriate) to help businesses that are suffering right now. Of course, we accept that this wouldn’t be a permanent increase by stealth and would expect the SEC to fully evaluate the impact of a temporary measure and report/consult further in due course as necessary, before a final long-term limit would be set. 

I trust that this submission is useful


Peter J Farmer, MA MSc MBA

Peter Farmer​ Director , Exonia Consulting +44(0)207 846 1303 | +1-(587)-316-7537 | 27 Old Gloucester Street, London, WC1N 3AX, UK #100, 100‑111 5th Ave SW, Suite 356 , Calgary , Alberta , T2P 3Y6 , Canada 3139 W Holcombe Blvd #A8, Houston, Texas 77025, USA 
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