April 25, 2020
In regards to II(A)(3) Question 18, it is my opinion that crowdfunding portals are already equipped to market Rule 506(c) offerings in the ordinary course of business and that only minor changes to the portals' procedures and systems would also allow them to vet the investor's status as accredited. The currently proposed changes in this notice already accomplish the task of giving a reason to portals to amend their processes and systems by treating accredited investors differently in the Reg CF offerings they are already listing. Many portals are already banding with affiliated entities to offer Reg D and Reg A offerings, all while using the same portal systems. It is my opinion that the current system used to allow the same online portal (website - not the entity) merely creates redundant work, additional oversight regimes, and thus increased cost, while basically utilizing the same distribution model and systems. Simplifying the process to accomplish that goal, thus seems wise.