October 5, 2012
After watching the video of the March 22nd conference: Access to Capital: Fostering Growth and Innovation for Small Companies. on the U.S. Treasury website, we believe that Beacon Investent Partners may be of help by commenting once again since the JOBS Act is born out of the second Panel Discussion of that conference. That session culminated in Kate Mitchell being asked to head the IPO Task Force which produced its work-product the Rebuilding the IPO On-Ramp: Putting Emerging Growth Companies and the Job Market Back on the Road to Growth report to the SEC, Treasury et al. Ms. Mitchell, Chairman of the National Venture Capital Association (NVCA), was on that second Panel and was tapped on the spot its moderator to head up that IPO Task Force.
That work-product is the genesis of the JOBS Act and the SEC is charged with making rules accordingly. I expect that the US economy stands to benefit, especially General Partners of Venture Capital funds, Investment Bankers and Broker Dealers.
That said, the existing Reg A rules have evolved since 1936 to the point where, once there is ready public access to A-1 filings, entrepreneurs can see examples like the Round Barn's ads and learn how to Test The Waters to a market of over 20 million everyday adults (no means test) in SEC-coordinating states where citizens are free to read TTW general advertising online, hear it on the way to work ...
The first Panel Discussion dealt with Pre-IPO Funding: Seed Capital Reg. A was never even mentioned and no task force was created by Moderator Tim Geithner. It was said, in a variety of ways, that most entrepreneurs don't know where to turn.
Of course there are happy exceptions like Peter Thiel who got in on the ground floor of Facebook, buying over 10% of the young company for $500,000.
When the SEC publishes the future A-1 Reg. A TTW ads and offering documents that the SEC reviews so that they can be found by search engines and employed in house by Do-It-Yourself entrepreneurs, then, with assistance from neighbors driven to bootstrap jobs in their own communities, we will see the kind of ground-floor movement our citizens can help to make happen in their cities and towns.
Please, preserve Reg. A. for John Q. Public's sake. Once again, the bifurcation of Section 3(b) of the 33 Act by Title IV of the JOBS Act suggests this is also the intent of Congress.
Thank you.