Subject: File No. S7-09-13
From: Mark Henry
Affiliation: Founder, Otherworld Pictures

April 11, 2014

I think crowdfunding is great provided that the avenues for crooks to work through are closed.

Third party trustees should handle collected funds to insure that the money is utilized as advertised. Collected funds and project income should be held in escrow accounts.

Project funds should not be released to project owners until the amounts necessary to complete the associated ventures are met. Project income allocated for investors should be dispersed by the trustee, leaving the remainder freely accessible by project owners.

Trustees should be registered after verification of longstanding reputations for integrity. Complaints against trustees associated with the handling of project funds and accounts should be accessible by the public alongside rebuttals from trustees.

Access to collected project funds should be tied to drawdown schedules submitted at the onset of projects. Modification to the drawdown schedules should require written explanations.

In the event of disputes or suspicion, both trustees and project owners should present their cases to arbitrators. The process for changing trustees should be simple yet documented.

Facilitators of crowdfunding platforms should bare some responsibility for verifying the legitimacy of proposed projects.

People with histories of financial crimes should be disallowed except on a case by case basis after the passage of ten years and the approval of a written explanation of their current mindset and intentions.