ABA Comments on Crowd Funding Regs

The  Federal Regulation of Securities  Committee of the Business Law  Section of  the American Bar Association sent the Securities and Exchange Commission their- comments on the SEC’s proposed crowdfunding regs that included:

  • it agrees that amounts raised using crowdfunding should not be aggregated with other concurrent exempt offerings;
  • it agrees that the investment limit for persons whose income or net worth exceeds $100,000 should be the greater of $100,000 or 10% of their annual income or net worth (with no set dollar cap);
  • they would limit the business experience disclosure requirement to one year, at most;
  • they would limit risk disclosure to what’s in the statute;
  • they urge the SEC to provide conditional relief from, if not an complete exception to, GAAP compliance for small issuers seeking no more than $100,000;
  • they urge the SEC to permit issuers raising up to $1,000,000 to provide financial statements prepared on an acceptable basis other than GAAP; and
  • they do not support an interim (i.e., quarterly) reporting requirement, but do believe that material events should be reported more frequently than on an annual basis.

See the full letter here: https://www.sec.gov/comments/s7-09-13/s70913-319.pdf


About JeffKoeppel

I am a corporate/securities attorney in the Washington, DC area. Prior to joining the firm, I was a Senior Attorney Advisor in the Division of Corporation Finance at the U.S. Securities and Exchange Commission. I am a member of the Bars of the States of Maryland, New York and the District of Columbia. You can also follow this blog on LinkedIn at: http://www.linkedin.com/pub/jeffrey-a-koeppel/0/63/5a9
This entry was posted in Broker dealers, Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, Film, FINRA, Funding Portals, Investments, Jobs, Legislative Intent, SEC, Small Business, Venture Capital, Wall Street and tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , . Bookmark the permalink.

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