Apr. 17, 2020
I believe extending the Regulation CF 4(a)(6) exemption to up to $5,000,000 is not in the best interests of investors. Regulation CF offerings and Regulation CF Annual Reports, unlike Regulation A+ offerings and periodic reports, are largely effected by issuers without the assistance of legal counsel. This is evidenced by a cursory review of many Regulation CF filings, and moreover, the Annual Reports, which demonstrate that a substantial number of issuers, if they are indeed filing Annual Reports, are not complying with the disclosure rules. This is in part, due to the lack of SEC oversight of 4(a)(6) offerings, which was designed to make is easier to raise smaller amounts of capital. In the interests of protecting investors and ensuring sufficient disclosure and information is provided to them, I do not believe it is in the best interests of investors to increase the size of 4(a)(6) offerings to $5 million, and larger raises should be governed by and subject to the SEC oversight provided by Regulation A+. Jeffrey S. Marks Alliance Legal Partners, Inc.