Subject: Harmonization
From: Robert Gregory

Jul. 10, 2019


I have been monitoring the progress of the Jobs Act since Obama first proposed it and have been as frustrated as anyone else with the limitations contained in the 2015 ruling: however I have come around on the SEC’s obsession with Accredited Investor status. Working class investors need access to their capital in emergencies; therefore liquidity and transparency need to be greater when their money is invested. 
AS a former Series 24 securities principal I understand that a common trigger for a customer complaint is the sell order. When an investor can not get their money back in the amount they have been led to believe its worth, there is trouble.
In private equity there are no “sell orders” as such, therefore investors who need access to their capital should seriously consider the suitability of any form of illiquid investment. It’s the combination of the investors need for access to their capital and the instruments liquidity that needs  to be aligned.  
Digital assets have two major advantages over traditional private equity. A verifiable cap table and liquidity. If the harmonization process gives proper guidance to expand alterative transactions and the data verified and made available via these expanded cap table requirements. All investors no mater the income or net worth will  have liquidity and transparency.
My business is called Educated Risk and I have been holding off on filing with FINRA for a portal designation in hopes that the negative selection stigma placed on the CF funded businesses by industry professionals dissipates; but its only getting worse. CF should be the saving grace of small businesses and a major driver of employment but current limitations; particularly criticism that the costs are too great as a percentage of capital basis. Raising the limit even to 2,000,000 per year and regulating total expenses like LP’s (9 percent?)  should allow industry professionals room to enter this space instead of denigrating it.  
I believe that through the use of distributed ledger technology, cap tables and direct exchange capabilities can be expanded with a few rules for small less frequently traded vehicals such as REG CF companies this asset class can be viewed as preferable as opposed to its current stigma. Businesses that are able to “self seed” because they have a loyal following that needs their product or service should be celebrated in a way that makes the companies desirable to the traditional series  A funds. Today that trend is going in reverse. Traditional Series A funds are considering only businesses seeded by what they consider “sophisticated angles.” One associate has a list of only 100 seed investors from which they will accept proposals. 
I would be proud to operate a portal that educated my investors and made sure they had access to their capital after a modest 1 year hold. CD’s have such limitations.
I was a registered person for 25 years and see only solutions to age old problems with the advent of digital cap tables and digital liquidity for private equity. Keep the guidance simple and leave room for the already regulated folks to participate and I would gladly reapply for my license’s. If there is anything further you would like to aske me my cell is 212 203 5499.
Robert Gregory  
Sent from Mail for Windows 10