August 19, 2013
Dear Ms. Murphy,
I have been an tech entrepreneur for several years now and hold an MBA from Stanford. In the past, I have started companies which resulted in billions of dollars in shareholder wealth creation. I am deeply concerned about SEC's pending Form D filing rules concerning startup fundraising process. The proposed rules make sense for established companies that have enough resources and processes in place. For startups, which are almost always in an unstructured and undefined mode trying to find the right path or product they create unnecessary, cumbersome and discouraging processes. Early stage companies are in constant mode of taking risks, which makes them super vulnerable and error prone.
Here's my simple question: Were these rules in place 10-15 years ago what would be the likelihood of Facebook or Google or Tumblr breaking them? What about Dropbox or Apple? Imagine "banning" those companies from fundraising for a year at their critical start-up phase. Let us please not put in place excessive rules and regulations that would suffocate American entrepreneurial ecosystem.
best regards,
Umed Latifov