Crowdfunding, The SEC Needs Positive Feedback

By Sara Hanks , CrowdFundBeat  Sr.contributing Guest Editor  CEO/Founder, CrowdCheck, Inc.

Here’s hoping that everyone in the crowdfunding community is planning to respond to the SEC’s proposals on Rule 147 and 504. Even if they think the SEC got it right. And that they will comment on all aspects of the proposals, even the bits that the SEC got right.

Here’s why. Let’s say the SEC proposes a rule that says companies must disclose whether pets are permitted at the company’s offices. Let’s imagine nearly everyone thinks “Well, that’s reasonable. I want to know how pup-friendly a company is.” They don’t comment because they assume the SEC will adopt the rules as proposed. But in the proposing release the SEC has asked whether this disclosure is appropriate, or whether some alternative form of disclosure, such as whether the CEO likes dogs, would be preferable. The Sneaky Dogs advocacy group doesn’t want anyone to know which offices might welcome dogs. Sneaky Dogs supporters write several comments letters advocating the alternative form of disclosure and no-one else comments. Now it looks to the SEC that the only people who care support the alternative disclosure, and that’s the way the rule is adopted. Despite the fact that nearly everyone loved the original proposal.

So if you like the way the SEC proposed the rules, TELL them. CrowdCheck will be drafting a comment letter, which we will likely post links to, and we are happy for people to copy chunks of it (or all of it for that matter) providing they pay attention to gerundives and do not insert “grocer’s apostrophes”. If you are feeling too lazy to even do that, just drop an message to the SEC saying “I support the proposal as drafted.”

This article was also published at:

http://www.crowdcheck.com/blog/sec-needs-positive-feedback

sarahanks

 

 

 

Sara Hanks, co-founder and CEO of CrowdCheck, is an attorney with over 30 years of experience in the corporate and securities field. CrowdCheckprovides due diligence and compliance services for online alternative securities offerings. Its services help entrepreneurs and project sponsors through the disclosure and due diligence process, give investors the information they need to make an informed investment decision and avoid fraud and help intermediaries avoid liability. Sara’sprior position was General Counsel of the bipartisan Congressional Oversight Panel, the overseer of the Troubled Asset Relief Program (TARP). Prior to that, Sara spent many years as a partner of Clifford Chance, one of the world’s largest law firms. While at Clifford Chance, she advised on capital markets transactions and corporate matters for companies throughout the world.Sara began her career with the London law firm Norton Rose. She later joined the Securities and Exchange Commission and as Chief of the Office of International Corporate Finance led the team drafting regulations that put into place a new generation of rules governing the capital-raising process. Sara received her law degree from Oxford University and is a member of the New York and DC bars and a Solicitor of the Supreme Court of England and Wales. She serves on the SEC’s Advisory Council on Small and Emerging Companies. She holds a Series 65 securities license as a registered investment advisor. Sara is an aunt, Army wife, skier, cyclist, gardener and animal lover.

 

Tags: , , , , , , ,

nov2017-fintech confernce-dc

HEADLINE NEWS

Former Blink 182 Guitarist Crowdfunding SpaceshipThe Onion (satire)UFO enthusiast and Blink 182 co-founder Tom DeLonge is crowdfunding a “public benefit corporation” whose first project is a proposed intergalactic spaceship. What do you think? “I've thrown away money on worse mus [...]

Real Estate Crowdfunding Firm Targets Institutional InvestorsInstitutional InvestorFirst RealFund has begun offering real estate deals to institutional investors on a crowdfunding platform. The New York-based firm will provide short-term real-estate investments in high-growth neighbor [...]

AOLThis 94-year-old WWII veteran is crowdfunding a tour of refugee camps across the worldAOLBut there's still a challenge Smith wants to complete: traveling to refugee camps across the world. For this reason he's launched a crowdfunding campaign on GoFundMe to help him fund [...]

This Farming Robot is Looking for Crowdfunding to Plant its SeedsInverseThe Salk Institute may have cured polio in its heyday, but these days it needs help funding its research endeavors. The San Diego-based nonprofit science hub is seeking $313,840 through crowdfunding efforts in ord [...]

Crain's Detroit BusinessSouth Oakland Shelter acquires HandUp crowdfunding platformCrain's Detroit BusinessIn what's being called a bold move, South Oakland Shelter, a Lathrup Village nonprofit that provides services to the homeless, has acquired San Francisco-based Han [...]

AdweekThe Brewers Association Is Launching a Crowdfunding Campaign to ...AdweekThe Brewers Association has released a tongue-in-cheek video to promote its crowdfunding efforts. YouTube: Take Craft Back. Share. By Erik Oster. |. 23 hours ...and more » [...]

ForbesThe Recipes For Crowdfunding Success On Kickstarter -- And What To AvoidForbesToo little is known about the recipes for a successful crowdfunding drive for a new product. And there is even less known about online drives, despite its meteoric success over the past decade. A 2013 [...]

LeaflyCrowdfunding Site Cancels Aid to California Wildfire Victims - LeaflyLeaflyWith the most devastating wildfire in California history laying waste to its members' homes and livelihoods, the California Growers Association responded in the ...and more » [...]

The SunMum slammed for setting up crowdfunding page asking people to ...The SunA MUM has come under fire for setting up a crowdfunding page requesting cash instead of presents for her son's birthday. Paramita Sarkar says nine-year-old ...Mum starts crowdfunding page so her son ca [...]

Tom DeLonge's new UFO academy is crowdfunding a spaceshipConsequence of Sound (blog)Now, DeLonge's first major initiative with the group is a crowdfunding campaign to launch a spaceship. A message on DeLonge's Facebook account announces the project: “Hello, my name is T [...]

CFB Finance

Syml
Lst Val
+/- Val
+/- %

Marketwired

  • Crowdfunding
  • Crowdfund
  • Peer to Peer Lending
  • FinTech
  • Reg A+
  • Reg CF
  • Crowdfunding USA

Press Release

CrowdFund Beat Media

lnkd.in/gXvUdRw On November 6th & 7th 2017, global thought leaders will convene at the 2020 #Fintech at Nati…lnkd.in/gQ62iJ5

Live Crowdfunding .tv

What's Next Step in Regulation A+ JOBS ACTS Title IIII :L Interview : Steve Cinelli with Brian Korn Securities and Crowdfunding/Peer-to-Peer Lending Lawyer, Watch more video library | Conference | Interview | Campaign Showcase | Research | Education |