May 3, 2020
Chairman Clayton,
I am writing this letter to offer support for the proposed changes outlined in Proposing Release 33-10763 that is currently in the 60 days public comment period.
The Coronavirus has devastated a large section of our economy, and small businesses in America are suffering most. That is because they do not have the resources to sustain a loss of revenue, and they will certainly not see strong support from the banks who traditionally do not lend unless there is collateral on the line.
Regulation Crowdfunding has brought access to capital for startups and small businesses with some limitations. I want to talk about the main limitation I see, which is the $1.07M limit. The proposed rule is to increase that limit to $5M, and I applaud it. I think this new substantial limit will attract thousands of small businesses who otherwise would have not thought this was a viable option for raising the capital they need.
I urge you to look into all possible legal authorities to raise this limit immediately as an emergency rule to help support the thousands of small businesses that need capital right now. Equity crowdfunding has not dried up and has continued even during large public market corrections.
I want to thank you for your leadership and support of the small business community.
Yours truly,
Howard MarksCEOStartEngine Crowdfunding, Inc., StartEngine Capital LLC and StartEngine Primary LLC