Mar. 6, 2020
To: Securities and Exchange Commission Washington, D.C. REF: Comments to Rule Making for File# S7-05-20 Facilitating Capital Formation and Expanding Investment Opportunities by Improving Access to Capital in Private Markets. March. 6th. 2020 We thank SEC and Chairman Clyton to considering to increase the maximum allowed funding from $1,070,000 to $ 5 Million, and to reversing the "whichever is lesser" to back as Congress originally intended in HR3606 Title III to, "whichever is more", regarding yearly income v/s networth. However we still advocating to increase the maximum allowed "crowdfunded stockholders" from the current 500 to 2,500, to make Regulation Crowdfunding really work. For example, during the first full year of operation of Regulation Crowdfunding, one of the most successful portal (intermediary) had over 102,000 investor members. (investors must stay with the same portal for a full year, according to regulations). However, the average member contributed only $400.oo USD for the whole year. NOT very much! (we understand, the following years that average improved somewhat) If we do the math, $400 X 500 only adds up to $200,000 USD, a long way even to the current $1,070,000, maximum allowed, much-less to do a second offering a year later as the Act permits it. We realize that with Accredited investors being allowed unrestricted investment, will much improve the chances to reach the maximum allowed under Regulation Crowdfunding, but with the proposed increase, once again, we will run out of "crowdfunded stockholders" before the campaign reaches that $5 Million USD cap. We appreciate if the Commission would include that important change as well. Respectfully submitted by, T.W. Kennedy, BE founder Regulated Funding Portal Industry Association Long Beach, California membership@RFPIA.org