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89 Days to Go for SEC Proposed Crowdfunding Rules

89 Days To Go

The SEC has provided specific qualifications as to the amount that can be raised within a 12 month period of no more than $1 million. This to me sounds reasonable, although I would have liked to see a larger maximum annual raise limit closer to $2-5 million. This could be based upon where a business is in its longevity as a going concern and profitability or gross revenues.

Investors are also limited in the amount they can invest in a 12 month period. Here the range has been set from $2,000 to no more than $100,000 based on income and net worth. I understand why these limits are being imposed by the SEC, and they have made it perfectly clear about their concern that investors could be preyed upon and be subject to fraud. Has anyone heard of Casinos? How about the New York Stock Exchange or NASDAQ? Ever hear of Wall Street?

There are 34 States that have Casinos. What surprised me was the number of legal gambling locations in California. I don’t see any laws or State and Federal guidelines limiting consumers as to how much they can loose in a casino.

Lets be real here. You can walk into any Casino in the country with as much cash as you want, and loose all of it in a matter of minutes. In fact the Casino management will be happy to provide you with a credit line, and use all of your assets as collateral, so you can loose even more than the cash you have in your pocket.

When will the Government require that any person entering a Casino provide proof of income and limit the amount you can gamble every year?

The SEC also regulates every Security sold by every Brokrage firm on Wall Street, including the NYSE & NASDAQ and every other Exchange. Have they issued similar rules limiting your investments on any of these exchanges? How many Billions of Dollars were lost during the last market crash?

Anyone can open a Brokerage account and invest any amount of money they please in any public company. Same goes for the Over The Counter Exchanges, Pink Sheet listings and sub-Penney stocks. Yes, you can buy a share of a company on the Pink Sheets for .0001 Cents. I don’t see any regulations limiting how much anyone can invest in any of those markets.


Remember this "Its the economy, stupid"?

Who do you think has a lot to loose if there was no limit on how much you can invest using crowdfunding?
Just fill in the dots.

IT’S .... STREET, ......!

The countdown for public comments regarding the SEC Proposed Rules has begun. The comment period ends in 89 days on February 3, 2014. The Proposed Rules can be found at

It is very important that you follow all the rules required in submitting a comment to the SEC. I have first hand experience with what happens to comments that do not follow the strict guidelines required in filing with a Federal Agency.

Your comments should be received on or before February 3, 2014. Specific instructions on filing comments can be found below and on the SEC or Federal Register link above.

We will explore some of the 295 questions in upcoming blogs as we continue to count down the next 88 days.

Make your voices heard and let the SEC know what you think of the Proposed rules.

Comments to the SEC may be submitted by any of the following methods:
Electronic Comments
§ Use the Commission's Internet comment form
§ (;
§ Send an email to Please include File Number S7-09-13 on the subject line; or
§ Use the Federal eRulemaking Portal ( Follow the instructions for submitting comments.
Paper Comments
§ Send paper comments in triplicate to Elizabeth M. Murphy, Secretary, Securities and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.

All submissions should refer to File Number S7-09-13. This file number should be included on the subject line if email is used. To help them process and review your comments more efficiently, please use only one method. The Commission will post all comments on the Commission's Internet Web site ( Comments also are available for Web site viewing and printing in the Commission's Public Reference Room, 100 F Street NE., Washington, DC 20549, on official business days between the hours of 10:00 a.m. and 3:00 p.m. All comments received will be posted without change; They do not edit personal identifying information from submissions. You should submit only information that you would like to make publicly available.

If you require further information, you may contact:
With regard to requirements for issuers, Sebastian Gomez Abero or Jessica Dickerson, Division of Corporation Finance, at (202) 551-3500, and with regard to requirements for intermediaries, Joseph Furey, Joanne Rutkowski, Leila Bham, Timothy White or Carla Carriveau, Division of Trading and Markets, at (202) 551-5550, Securities and Exchange Commission, 100 F Street NE., Washington, DC 20549.
Elan Amram
Question by SEC #10. Should we adopt rules providing for another crowdfunding exemption with different investment limits (e.g., an exemption with a $250 investment limit and fewer issuer requirements), as one commenter suggested, [52] or apply different requirements with respect to individual invest...
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