Subject: File No. S7-08-19
From: T. W. Kennedy, , BE.
Affiliation: Regulated Funding Portals Industry Assoc.

November 7, 2019

RE: The Capital Raising Exemptions Within the Framework of Regulation Crowdfunding:
We find it necessary to reverse HR3606 Title III-s "whichever is less" back to "whichever is more" as Congress in HR3606 originally intended. (That is Networth v/s Income).
Also the maximum allowed to raise currently is $1,070,000. That should be increased to $10,000,000, to keep up with the times, and encourage more Issuers to participate.

Regarding Investors limitations:
The maximum "crowdfunded shareholders" at this point is 500 only. Since the First full year's average yearly investment
per investor was $400.oo USD, that would work out to $200,000.
A far cry to the maximum of current $1,070,000, and obviously no chance for a second offering a year later as HR3606 Title III permits it. (someone needs to do the math there)