August 9, 2011
I wish to note that the Regulation A offering, as it currently exists, is a real benefit to small business. The straightforward nature of the required documentation makes it largely unnecessary for expensive attorney involvement in "uncomplicated" offerings. Also, not requiring audited financials saves the small business at least $15,000 in preparing the offering in these post Sarbanes-Oxley days. Finally, the "testing the waters" provision helps keep small disadvantaged firms from wasting time and money if they cannot find a reasonable market for the offering.
If anything, add an even simpler format for the offering circular that does not include language for the more complex securities or things like warrants and options since the majority of small firms don't have these things in the first place.
Otherwise, as the SEC updates its rules and regulations, please keep the small business, and not lawyers, venture capitalists, investment bankers, and CPA's, at the forefront of who should benefit from small business changes.
Thank you
Nick Granny