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From: Finn Terdal
Dear SEC, I would very much support two key amendments to Rule 147. 1. Offerings made in reliance on rule 147 should be able to be viewed anywhere, but only purchased in-state. These days, most marketing and advertising is done online, particularly in social media (e.g. Twitter, Facebook). Limiting offerings to intra-state advertising is a crippling disadvantage. 2. There should be some kind of "local company" test. Requiring that the issuing company be registered in the state where the sales occur is a rather crude measure of "local", since many companies are registered in Delaware but do essentially no business there. A more appropriate test of a "local company" would be one that has at least 80% of the employee wages paid in state, or perhaps 80% of the work (i.e. manufacturing, producing, brewing, etc) be done in state. These are just a few ideas, but something similar would suffice. Thank you for your time and consideration. I eagerly await news about changes made to rule 147. Sincerely, |