December 10, 2013
I'm concerned that the $1,000,000 cap per calendar year is too restrictive for the Section 5 registration exemption-- a group of HOAs may wish to crowdsource among residents to make a real estate deal. SEC can reccommend an additional exemption for crowdsource offerings that are primarily used for down payment on loans for property purchases. The risk of putting $1,000,000 into a tech start up is significantly different than putting $2,000,000 as 20% down payment on the purchase of a $10,000,000 commercial development.