January 11, 2016
My thoughts on the three committee recommendations:
1) I support the first recommendation stating that offers made in reliance on Rule 147 can be viewed by out of state residents, but sales made only to residents of the state in which the issuer has its main offices.
2) I support some sort of test to make sure the company is local, that is different from the current 80% rule. At minimum, the head office should be located in the state.
3) I do not support eliminating the requirement that the issuer be incorporated or organized in the state where sales occur. If the company is incorporated in the state where sales occur, it is another way to encourage local funds to be retained locally.