May 14, 2020
The proposed rules are very much needed and I concur with them in their current form, particularly the regulations for Regulation CF that mirror the IGE intrastate offering we have here in GA which has been helpful.
The only pause I have is for Rule 506(b) of Regulation D and why there would be a 90 day limit for up to 35 sophisticated but unaccredited investors. If the objective of these rules is clarity and streamlining, I would think not having a day limit would help with that objective.
Thank you