Subject: File No. S7-09-13
From: Alexandra D Holland, Ph.D.
Affiliation: CEO and founder of PIARCS, PBC

June 3, 2014

Please move the JOBS act forward, but address the following issues.

First, I feel that the limit of $2,000 for someone who earns between $40-100k per year is highly intrusive and quite un-American. As if the SEC prohibited a person to buy a car or a trip on a cruise?

But first thing first, now, the current status is a $0/year for anyone earning under 200k/year. So please, move the JOBS act along and address the following issues:

1) The proposed rules require a company which seeks to crowdfund more than $500,000 (including prior crowdfunded offerings in the prior 12 months), to provide two years of audited financial statements when it files its initial offering materials with the portal and the SEC. PIARCS is a startup and this is very limiting.

2)Restrictions on Compensation Paid to Crowdfunding Platforms

3) Unnecessary Liability for Funding Portals

4) The Prohibition Against Curation by Non-Broker Dealer Intermediaries

5)Complex Non-Financial Disclosure

Thank you.


Alexandra Holland, PhD