Subject: File No. S7-06-13
From: Jeff Kinsey
Affiliation: Entrepreneur of 30+ years

August 17, 2013

Once again, the SEC has no idea how small businesses are created. Small in the real world means a thousand bucks is a month or two of "runway". Runway is a startup term. Check wikipedia. Founders often go months without any compensation. Your amendments offer penalties that are much better suited to companies that already have money. How sad. Clueless.

Is there ANYONE at the SEC that actually understands the tech startup scene?

It does not seem likely given this heavy handed view of reform.

You do know the Equity based Crowdfunding regulation was by law supposed to be in place by December 31, 2012. Yes, after waiting over 200 days after the JOBS Act was signed, nothing has happened. Zero.

Today, we are 229 days past that date. Over 400 days and ZERO.

Soundbyte leadership is destroying this country's job base aka as small business. Your amendments lack any real understanding of the problem.

Short of everyone at the SEC resigning, how do we fix this?

But know that I am very comfortable with the thought of replacing the entire Commission. It is not possible the replacements could do any worse, given the only hard requirement for employment that I would impose: Each and every employee would have actually owned a business and had to "make payroll" for at least 90 days for at least one employee.

It really is that simple.