November 5, 2019
Hi,
I will address your questions one at a time for each one that I have a response for.
Capital raise - Reg CF cap should most definitely be raised to 4 million as Wyoming has done.
Potential Gaps - it is extremely cost prohibitive for small companies to raise funds in the US with current guidelines other than Reg CF which doesn't allow for enough raise.
Investor Limitations - at no time in history or present does the amount of money someone has make them an accredited investor, these laws need to change. Any person that has been licensed to sell securities should be accredited and anyone that can pass a test similar to SIE. I think SIE is too broker directed so something that is more investor directed would be better.
Integration - this should absolutely be a goal of the agency.
Pooled Investment - this should absolutely be undertaken and investors allowed to participate in closed-end funds of course with all proper disclosures.
Not on your list is the prospectus rule. While as a former RIA I understand the rule, it is a straw man argument because the average investor can't read and understand a prospectus. If disclosures are to be required, and they should be, then it should be in a format that is understandable to the average investor, not just attorneys and investment professionals.