September 1, 2013
Dear Sir or Madam,
I think the regulations have laudable goals that will be better achieved through alternative means. As an active angel investor, former Google Engineering Manager and current partner in a Venture Capital firm. I have an active interest and a great deal of insight in to these issues.
The easiest way I could express my opinions is to ask that you pay close attention to the opinions of Naval Ravikant and AngelList. They have done a lot of good for the community already and I expect will do a lot more again in the future.
1. Allow third parties to do the filing on issuers behalf via API
2. Allow the company (or a third party like AngelList) to hold the financing materials so the SEC can access them.
3. Only require legends and disclosures when terms are communicated, rather than general information that financing is occuring.
4. Drop the 15-day-in-advance before financing rule entirely.
5. Dont impose death penalties for noncompliance. Instead, reduce the costs of compliance by making more Form D information confidential rather than public. Then automatically release the information after say a 1 or 2 year period.
6. Dont be overly broad in the penalty application. There are many businesses like AngelList, incubators, and VCs that surround startups, that should be protected even if there are small issues within the community.
Thank you for your consideration.