• Note to the SEC on Accredited Investor Definition

    8 June 2014   The Honorable Mary Jo White, Chairman US Securities and Exchange Commission 100 F St. NE Washington, DC  20549   RE:  Accredited Investor Definition   Dear Chairman White:   As a board member of the Angel Capital Association (ACA) and the Chair of the Seattle Alliance of Angels, I urge the Commission to protect angel funding to

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  • Comment to the SEC

    November 4, 2013 Elizabeth Murphy, Secretary U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549   Re: File No. S7‐06‐13, Amendments to Regulation D, Form D and Rule 156 Dear Ms. Murphy: Thank you for the opportunity to provide comments to the Commission on your proposed amendments to Regulation D and Form D.  Many others have provided

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  • Why is the ACA making a big deal about the SEC proposed ruling?

    I am being asked, why is the SEC proposed ruling such a big issue? Unless you read the entire ruling and get to talk either directly or indirectly to SEC staff, it doesn’t seem like a big issue. Simply put, the proposed SEC ruling is (a) trying to fix a problem that doesn’t exist; (b) will increase risk in our

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  • Too Much Complexity, so Tell the SEC

    As a rule I live by, “if it ain’t broke, don’t fix it!” The new SEC rules violate that basic principle (see: http://www.startuplawblog.com/ or my previous posts). There is virtually no fraud in the Angel Investing asset class, but the SEC has decided to impose (without a Congressional mandate) stringent new rules that will cripple angel investing. Let me use

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  • They’re at it again!

    The SEC just announced some new rules, based largely on the requirements of the JOBS Act. These rules, on their surface, seem really great. They acknowledge the rise in angel investing by allow companies to seek out angels nationally via “general solicitation.” Unlike Crowdfunding, which allows companies to seek investment from the general public, these rules apply ONLY to accredited

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