March 3, 2014
I would like to weigh in on how essential a coordinated blue sky registration is to this regulation A proposal. There must be 1 stop blue sky for all 50 states. Not allowing this will kill the regulation A proposal. Imagine driving your car from Virginia to California and having to stop in each state along the route to have your car inspected according to that state's regulations. Sound ridiculous? Well, that's what individual state review requires a securities issuer to do now relative to blue sky filings. We must adopt a modern approach, saving issuers valuable time and tens of thousands of dollars.