Subject: File No. S7-06-13
From: Andrew Antar
Affiliation: Founder,

August 20, 2013

The government can't bully startups into compliance they way it can to public companies who have tons of resources to remain compliant. A 1 year ban is preposterous. It should flip the requirements: startups have a year to report to SEC that they publicly advertised fundraising, and up to a year to report changing the deal terms, and a $200 slap on the wrist if they take longer. This would allow startups to fundraise freely without fearing the SEC and government, while still allowing the SEC to collect useful data on successful rounds.