Subject: File No. S7-06-13
From: Andrew Schulz
Affiliation: Startup Founder

August 14, 2013

My startup is entering its seed funding stage and the current state of this amendment will at least require us to spend our scarce resources understanding the new funding guidelines and ensure our investors meet all accreditation requirements and at most the complexity and large margin of error could trigger the 1-year fund raising ban which would kill the company.

I understand the need to set guidelines for accrediting investors to reduce fraud but if there is going to this strict of a penalty for not doing enough of a background check on potential investors then there needs to be some sort of support in the amendment to streamline that process and reduce the costs for resource strapped and early stage companies like mine can comply. Even then, the penalty in its current state is so strict that it will likely dissuade my company from looking at general solicitation as anything but a last resort for funding raising rather than the robust and catalystic force it should be and was like the original intent of the bill.