Subject: File No. S7-06-13
From: Michael Mian, PhD
Affiliation: VP Business Developement, Nodeprime

August 17, 2013

I think the 1 year ban is a little draconian. While I understand the need to provide an incentive for start-ups to be diligent, I think that young entrepreneurs could easily fall foul through no fault of their own due to receiving bad advice, particularly during the time immediately following the instatement of this amendment. So I would request that some period of time immediately following the enactment of this amendment a grace period is allowed for business to get things right and perhaps a 3-strikes rule is applied before the 1 year ban.

The need to protect the general public from fraudulent operations is important, however small entrepreneurial businesses are unlikely to have the resources to deal with heavy documentary requirements on strict timelines due to their limited resources, while for professional fraudsters will have no trouble meeting the compliance deadlines. I would suggest that the filing deadlines should be extended to 45 days from 15.