Subject: File No. S7-06-13
From: Adam Geller
Affiliation: Startup CEO

August 20, 2013

I'm worried by the new penalties that might be levied against a company for improperly announcing a funding round. A one-year penalty to raise more funds could mean the end of many small companies which are raising small amounts more often in a milestone-based approach. These rules might work fine for a large company with a large legal team, but startups don't have this luxury.

I understand why you'd want companies to register in advance -- this could help create more transparency and even provide a clearinghouse for data. If this is the case, then the barrier to entry here must be lowered such that lawyers don't need to be involved before the process even starts and funds are available. Create ways for automated tools to exist which would handle the process more effectively for a small company.