Subject: File No. S7-09-13
From: Andrew Martin, OFS, CB

October 18, 2014

Dear Sirs,

I fully agree with your proposed crowd funding rules.

I personally believe that equity crowd funding should be operated through a trust fund mechanism which in turn would own shares (voting or non-voting) of the entity seeking crowd equity funding.

This would be similar to the concept of a mutual fund, except instead of being invested in publically offered investments, the fund would be specific to a small entity seeking the crowd funding and not made available for trade on the open markets (although there should be a way for people to cash out and get a return of their invested dollars).

Further, I think the SEC should seek the investing banking community to help provide the necessary compliance by setting up means for small start-ups to obtain the necessary required filings and maintain the needed documentation to equity crowd funded holders.

This kind of compliance could easily be done through a website and a small fee could be charged. This way the investment banking community would be participating guardians of this new investing method. It would also allow for easier review by the SEC since these records could be centralized and ensured compliance with filing requirements.

Thank you for time with my comments.

Andrew Martin OFS, CB