17 Mar Regulation A+ Comment Deadline Looming!

One of the biggest changes in the regulation of capital formation by smaller companies is coming. The revisions to SEC Regulation A, mandated by the Jumpstart Our Business Startups (JOBS) Act of 2012, have been proposed by the SEC. Comments must be submitted no later than March 24, 2014. A number of important constituencies and bar associations have submitted or are submitting comments to the proposed rule changes, which we have overall supported strongly in this space. For more on the Regulation A changes and the sea change they could bring about, just search “Regulation A” in the top right corner of this page.

The SEC unofficially says they do look at comments when they are submitted after the deadline, but not once they are basically done writing the final rules taking into account the comments (or not taking them into account which is sometimes the case!). I spoke on a webinar last week along with Rep. Patrick McHenry and my colleague Sam Guzik. Congressman McHenry correctly implored listeners to make sure their voices are heard as these changes are made. As good as the proposals are, they could and should be improved. And certain key legal issues should be clarified. To see letters that have been submitted so far, go to www.sec.gov.

Government works best when they hear from the folks. Productively, constructively, respectfully, be heard!