February 3, 2014
February 3, 2014
Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Submitted via email: rule-comments@sec.gov
Re: Comments on Proposed Rule: JOBS Title III - Language requirements for educational other materials forms.
Education then, beyond all other devices of human origin, is the great equalizer of the conditions of men, the balance-wheel of the social machinery. — Horace Mann, father of U.S. public education system
Dear Ms. Murphy:
Thank you for the opportunity to provide comments to the Securities and Exchange Commission (the Commission) on its proposed amendments.
We would like to get Commissions attention on the issues of small business owned by foreign born immigrants. As you all know, first generation of Americans from overseas are major drive forth of economy of our nation. Portuguese bakeries, Chinese restaurants, Vietnamese hair salons, Russian grocery stores, Brazilian furniture stores, Indian newspaper stands, apartment repair shops run bay Mexicans. They may not speak fluent English and they may not be completely assimilated into the US culture, yet they also are US citizens struggling to survive, educate next generations of Americans, at the same time, creating wealth and jobs to our society. We believe that they are equally deserve to take advantage of JOBS act which aim to democratize investment opportunities among mass and to provide opportunities for small business and emerging companies to access capitals. Unfortunately, foreign born immigrant small business owners have disadvantages over preparing sophisticated document in English required by JOBS act. The commission should consider availabilities of documentations, education materials and other necessarily resources in multiple languages. The commission also may want to consider outreaching program of specifically to these foreign born immigrants business owners.
All citizens should have an opportunity to invest in local businesses. Many of them cater to local community taste communication method. Solicitation on a farmers market from legal standpoint is not any different than solicitation on the Facebook.
All American citizens must have access to opportunities simultaneously. No matter what language issuer is delivering solicitation. No matter what communication media is used it would be very difficult unless
1) It should be possible to submit majority of documents in the native language as long as basic investor education requirements solicitation were done in the same language
2) Get rid of forms with questionable value.
3) 3-6 months test trial with English language documents, education, testing, certification, etc.
4) 1 to 3 month review period
5) 1-3 months localization for selected languages limited # of docs.
We appreciate this opportunity to comment in advance of the proposed rulemaking for the JOBS Act. Should you have any questions or require any additional information about the Advisory Council or the contents of this letter, please feel free to contact me at 617-879-4710 or agimpelson@rcn.com