Subject: File No. JOBS Act Title III
From: Christopher R York
Affiliation: CEO, NaviGantt

January 27, 2014

As I see it, one of the biggest problems with crowd funding is the potential for fraud or the appearance of fraud. Investors must rely on the unreliable projections and valuations of entrepreneurs. Proposed rules include very expensive and time-consuming audits, disclosures and financial statements. Even with these expenses the most honest and well-meaning entrepreneurs might appear to have provided fraudulent claims when their ventures don't deliver the results they expected.

Dynamic Equity Models like the one described in Slicing Pie, however, could eliminate much of the need for convoluted valuations and predictions of the future. If all crowd funding was managed with a Grunt Fund everyone would be treated fairly no matter what the outcome

Copyrighted material redacted. Author cites:
Moyer, Mike. Slicing Pie: Funding Your Company Without Funds. Lake Forest, IL: Lake Shark, 2013. Print.