September 15, 2013
To the SEC,
Thank you for protecting the public interest. There is nothing worse than investing money in less than fully honest or unprepared enterprises. On the other hand, there is nothing more satisfying than seeing new businesses successfully bloom and grow. Crowdfunding has been a means of achieving what for many decades has been impossible for entrepreneurs - raising funds through customer prospects, friends and philanthropists, not just accredited investors. Now, with the JOBS Act going into effect we would like to add our voice in asking for a few things that will make the changes effective for entrepreneurs. Specifically ...
1. Make any forms for compliance easy to understand easy to find easy to complete.
2. Remove the one year cooling off period for those not in compliance. Reserve it for repeat offenders or for more serious offenders.
3. Supply a web interface and API for timely paperless submission and storage of any attachments.
4. Do not require the filing of materials used via social media platforms and other web media as proposed in Rule 510T.
5. Do not require advance filing of Form D. We are in agreement with those in the crowdfunding business we support. It will produce less burden on the SEC as well as on the start up community if only those filings which actually result in exchange of money need to be filed. We suggest requiring Form D only after the first sale of securities for offerings generally solicited.
I thank you for the work you do. I believe that if you will tend to these details prior to implementation of the new regulations we will all see the best results.
James Carvin, Director