September 3, 2014
Dear SEC Professionals:
My comment is simple and to the point. I am extremely disappointed that your proposed regulations for Tier 1 issuers, which still requires the onerous burden of being subject to state registration requirements. This lack of relief for the smallest of issuers makes the legislative changes to Regulation -A nonexistent for its intended beneficiaries. Again, and far too often, the smallest businesses are left with nothing that their elected officials intended them to receive. The current Reg. A regime was only used by what will now be Tier-1 companies. Under the proposed rules these companies will still be subject to hours upon hours of duplicate registration. I am very disappointed in the lack of vision that the Commission has demonstrated and little regard for the smallest of business struggling to raise capital across the entire country using the tools of the 21st century.
I am still hopeful you will see the importance of correcting this oversight and righting an injustice in the capital raising universe.