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.”