Subject: File No. S7-06-13
From: Bettina Hein

September 13, 2013

1. Under the proposal, firms or startups must notify the SEC 15 days before they publicly discuss raising money.
My comment: This is doable if you make it electronically more easy to do this. Currently, the process seems to be stuck in the early 2000s and is very cumbersome.

2. Firms/start-ups must file documents with the SEC every time they update their offering materials.

My comment: This is very onerous for very small firms (1-5 person companies). The only way I envision that working is that the SEC provides electronic APIs to crowdfunding platforms that then allow automatic resubmission every time you change something. An alternative is to be extremely vague in what you submit so that it doesn't have to be changed frequently. On average, young companies at an early change their plans about once per month.

3. Firms/start-ups must include legal boilerplate every time they talk about their financing publicly.
My comment: As long as the requirement for this is publicized widely enough and the boilerplate is short enough to fit in small print on a slide, I think this is manageable.