November 11, 2013
1) The Commission should not require that amounts raised in non-securities-based crowdfunding efforts to be included in the calculation of the $1 million limit.
Securities-based crowdfunding has the potential to reach beyond stand alone start-ups and positively impact large public corporate RD by allowing spin-outs to self fund. A large corporate parent may have many other crowdfunding efforts going that are unrelated to developing new companies and those activities should not count against the $1 million limit and potentially undercut the parents companys ability to spin out new start ups.
2) Institutional and accredited investors should not be subject to the investment limits.
While protecting individual investors making multiple small donations is critical, this securities regulation exemption will open up crowdfunding to professional institutional and accredited investors. Issuers, and in this case intermediaries, have an incentive to choose larger investors over numerous smaller investors due to the lower cost of dealing with fewer investors. In addition, professional investors seeking control in early stage organizations will have a further incentivize to participate given the fact that they can purchase a controlling interest initially.