It sounds like you basically want Rule 506 offerings without the accredited investor requirements. Debate over the wisdom of that notwithstanding, this was never the intention of the crowdfunding portion of the JOBS Act to begin with.
It sounds like you basically want Rule 506 offerings without the accredited investor requirements. Debate over the wisdom of that notwithstanding, this was never the intention of the crowdfunding portion of the JOBS Act to begin with.
I disagree with your interpretation of the intention of the JOBS Act. As I interpret it it's meant to allow all Americans the opportunity to invest in startups and small businesses while protecting them from losing all their money. Introducing regulations that cause severe adverse selection outweighs the benefit of those specific rules, in my opinion.
[1] I think the quality of companies raising publicly on Wefunder and AngelList speak to that, but I'm heavily biased. I respect your opinion even though I disagree with it. :)
Because you don't want people gambling with money that they can't afford. These regulations are about protecting investors while still opening up funding for startups.
As for how the market is behaving: I have personally heard several attorneys state that they're advising their clients to be very cautious about Rule 506(c) and according to media reports[1], this is the advice of many attorneys.
I am aware that companies are relying on Rule 506(c) for offerings on AngelList and services like yours, but in terms of the overall market for Regulation D offerings, this is a still a small number.
> I disagree with your interpretation of the intention of the JOBS Act.
You cited the $1 million cap as an example of a rule that is of concern to you. To my knowledge, this cap was an explicit part of the bill that Congress passed. As such, I don't see how the SEC could eliminate that restriction.
[1] http://www.crowdsourcing.org/editorial/ban-on-general-solici...
That's true, there's definitely subjectivity here. I make the assumption that YC companies are a proxy for "healthy, high-caliber" startups and my opinion of what will be deal breakers for that category of company is shaped by our customer development in the YC network. I could be wrong for a few reasons.
> As for how the market is behaving: I have personally heard several attorneys state that they're advising their clients to be very cautious about Rule 506(c) and according to media reports[1], this is the advice of many attorneys.
Indeed. I think there's a natural lean for attorneys to be more conservative and wait for things to play out a little. I believe that in the next year or two it will be commonly accepted, I've already seen a lot of attitude change over the past year. We'll see. I think this is something startups ultimately want - assuming all the concerns can be addressed. More fundraising options and a wider pool of value-add investors is a good thing if crowdinvesting can be done practically, IMO.
> You cited the $1 million cap as an example of a rule that is of concern to you. To my knowledge, this cap was an explicit part of the bill that Congress passed. As such, I don't see how the SEC could eliminate that restriction.
I did, in the 585 page document the SEC released they suggest a few adjustments to address the concerns people have. For example, the $1m limit might be applied to the fees collected by the funding portal.
I disagree with this. I'll take advice from 2 people that I trust and admire before I'll poll 10,000 people. In my opinion, it's a distraction. That's why I believe it to be more valuable to have a couple of very smart & helpful investors rather than a lot of people with individual opinions and voices.
Maybe a little off-topic, but in some ways, this is what I admire about Steve Jobs, is seeing what people wanted before they realized they wanted it. I don't know if it's real or not, but the quote attributed to Henry Ford, "If I had asked people what they wanted, they would have said faster horses" does hold a grain of truth. He could cut past the noise of the crowd to see the potential of an idea. Ask someone in 2004 what they wanted in a phone, and "bigger" probably wasn't on the list.
You can already do that, they should buy your product. If they are so jazzed about it, they should tell their friends, and it should be easy for them to do so through whatever your product is.