NSBA Comment Letter to SEC on CrowdfundingFebruary 11, 2014
On Oct. 23, 2013, the U.S. Securities and Exchange Commission proposed new rules to implement Title III (re: crowdfunding) of the JOBS Act and requested comment on the same. The JOBS Act was signed into law by President Barack Obama on April 5, 2012 and was designed to transform the ability of startups and small business to access the capital they need to grow their firms and hire new employees.
In response to the SEC’s request for comment, NSBA filed a general comment letter on Feb. 3, 2014 discussing how several of the proposed provisions would both facilitate and unnecessarily impede small businesses’ ability to raise capital. NSBA’s comments focused on a number of issues ranging from how exclusing amounts raise in other offerings would help make crowdfunding successful to how the proposed 3-year look back provisions regarding tax returns and the lack of guidance with respect to required background checks could make crowdfunding cost prohibitive.
Please click here to read NSBA’s letter.