Subject: File No. S7-06-13
From: Nancy Girouard
Affiliation: CFO

August 20, 2013

I am a CFO with 12 years of experience in both early start up companies and public companies, where I have done SEC reporting (10Q, 10K and S-8's).

Having worked with lean start up's I can attest to the general lack of financial leadership in the executive team. Often these are young entrepreneurs with promising technology that can make the world a better place but don't have the funds to pay a person with sufficient experience, like myself, to help them navigate complex compliance requirements set by an organization such as the SEC.

I participate at investor panel pitch events regularly (once to twice a week) and I can tell you that less than 15% of the start up companies I talk with understand the role the SEC plays and how it can affect them even if they aren't public yet when it comes to fundraising.
Going without funding for one year will easily kill over half the start up's in Silicon Valley.
There is significant momentum since our last economic downturn and creating requirements such as this will hinder future growth of important companies.


Nancy Girouard