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 ensure …
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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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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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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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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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Frequent readers of my blog know that I am active in public policy on behalf of angels. They also know that I am a nerd and about as far from a lawyer as you can get. So, they should take this post in that spirit.
When angels purchase stock in a startup, they must certify to the issuer that they …
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As the VC market has (in general) moved upstream to later and later-stage deals, angel investors have filled the breach by not only investing at the seed stage, but also carrying deals through to exit. As a result, an increasing number of angels are joining groups (like the Alliance of Angels). As these groups reach their capital capacity in a …
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My first photo book, Pantanal Magic, is now available for pre-order. Cost will be $100 per book and 100% of the proceeds will go the Seattle Humane Society (www.SeattleHumane.org) and Washington State University College of Veterinary Medicine (http://www.vetmed.wsu.edu/). To see a preview of the book, go to www.rosen-photo.com and click on the Pantanal Magic Book link. …
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Once again, through inadvertent action, the federal government is about to threaten Angel Investing. This all started as a way to increase investment in startups, when congress passed, and the Obama signed the JOBS Act (see: http://blog.drosenassoc.com/?p=97). Title II of the JOBS Act allows “General Solicitation and Advertising” of private placements (like Angel deals). One would think this is …
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As you know, I chair the Public Policy Committee of the Angel Capital Association (http://www.angelcapitalassociation.org/). In that regard, I’ve spent a bunch of time in Washington, DC, meeting with legislators and executive branch people. I thought it would be useful to post a simplified version of the story we tell.
It still surprises me, being so immersed in …
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