As the clock ticks down to Dec. 31, it is becoming more clear that the SEC’s crowd funding rules are going to have to be a work in progress, regardless of how detailed they turn out to be. Crowd funding is a blank slate concept where new twists surface every day. Witness the claim that providing a product sample may be considered to be “investment advice” in a recent Washington Post article about the Reg. D crowd funding website Circle Up. Is it? What if C-Up just told the investor what store to buy the product in? Less of investment advice?