Subject: File No.
From: Vinh Nguyen
Affiliation: Licensed professional engineer

September 13, 2019

Intrastate crowdfunding exemption requires investor funds be directed into an escrow account at a bank in the same state where the offering is made. While the reasoning behind this is obvious and why it is required is understandable. Unfortunately, in reality, no bank offers escrow services unless it is for real estate purposes, mortgage for example. This has resulted in no offering made through intrastate crowdfunding exemption in many states.