Aug. 25, 2020
Subject: Final Reg CF Rules Hello Sebastian, I hope this finds you well I want to bring to your attention the need for a change in a proposed rule change for the new REGCF rules related to syndication. The current rule allows for syndication however it’s in conflict with the rule that offering can only appear on one registered funding portal at a time. This rule should be revisited to allow for multiple funding portals to host a offering with a syndication agreement in place or filed with the regulators perhaps with the offering at the time of issuers initial filing. The history of REG CF issuers not raising capital to the limits of the current 1 million dollars with a single portal leads to the need to syndication with the increase to 5 million dollars over whelming supports the need for REGCF offering syndication the (tombstone) and related documents should be allowed to be on multiple portals which is current prevented in the FINRA rule. The spirit of the syndication was in the rule however it resulted in bad policy. Please kindly forward to SEC REGCF review team. All the Best Mark Jones CEO Sprowtt Inc.