March 4, 2013
Restrictions on soliciting share offerings should be relaxed, but not lifted entirely. They should however be limited to forums where the audience is disproportionately investment educated or accredited.
In the beer industry we carefully control our advertising such that it squarely hits predominantly the eyes of those people of legal drinking age. We have set audience age composition requirements that must be surpassed before we can advertise.
This same logic should apply to soliciting shares. We should be allowed to advertise share sales via median and forums where the audience is disproportionately accredited or intimately familiar with the risks of investing.
For example, were we to advertise shares on CNBC, on Etrade, or in the Wall Street Journal (or potentially any newspaper's finance section), we are going to be talking disproportionately to the savvy investor. On a similar note, putting an advertisement into a publication with a significantly upscale distribution should disproportionately engage the accredited investor.
Similar to how we deal with beer advertising, we should be required to research audiences prior to advertising share availability. But it should be legal, given appropriate controls and responsible placement.
Thank you,
-Ian Schuster
President
Schubros Brewery LLC