August 17, 2013
Are you guys and gals just trying to mess up entrepreneurial fundraising?
Your proposal appears to be targeted to the way startups raised money 20 years ago: with long prospectuses designed by bankers who were facilitating the deal. Today, startups raise money without bankers, through informal conversations with investors. It is unfeasible to notify the SEC in advance, file documents every time there is a new communication with investors and include boilerplate with every communication.
Please advance to the 21st Century and make realistic rules for today's fluid and open business society.
I encourage you to continue to try to protect investors. But not at the expense of small and startup businesses seeking capital. And DEFINATELY not to LINE THE POCKETS of lawyers and bankers. They are NOT the solution, as they have proved time and time again (remember the mortgage fiasco?). Take some risks, give responsibility to the small businesses and investor communities, and watch - see what happens - adjust. Do not require boilerplate death (which no one reads anyway), nor unfair pre-notification requirements.
Thank you in advance.