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How does CfPA address challenges related to crowdfunding vehicles, including the need for clearer guidance, removal of the $25M asset cap, and consistent regulatory treatment of Series LLCs?
Thank you for a good question! This topic aligns closely with CfPA's policy platform, and here is our position on the matter.
Crowdfunding Vehicles and Avoiding the Registration Requirement
The CfPA supports the following changes.
i. The rules governing crowdfunding vehicles (“CV”) are challenging t... more -
How do you view Reg A crowdfunding deals compared to traditional IPO deals?
The larger Reg A crowdfunding deals I've followed tend to be high-risk. The companies have gone to crowdfunding, in part, because they've likely struggled to convince VCs to invest. That they can go to the crowd to raise is great, but I fear investors are participating because of exceptional marketi... more
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How does CfPA propose addressing restrictions on portals raising funds on their own platforms?
Thank you for a good question! This topic aligns closely with CfPA's policy platform, and here is our position on the matter.
Crowdfunding by Portals
We support allowing portals to raise funding on their own platforms as long as the relationship is fully disclosed and the number of raises is limited... more
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What measures does CfPA recommend to ensure issuers understand portal fees, privacy policies, and crowdfunding vehicles in Reg CF offerings?
Great question! This topic aligns closely with CfPA's policy platform, and here is our perspective on the matter.
Disclosures to Issuers
Issuers must receive clear and complete disclosures regarding portal fees, privacy policies, and the use of crowdfunding vehicles. Portals should be required to pr... more
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What is CfPA's stance on simplifying Reg CF investment limits and advertising rules to reduce confusion and improve accessibility for issuers and investors?
Thank you for the great question! This topic aligns closely with CfPA's policy platform, and here is our perspective on the matter.
Simplification of Rules
We support streamlining overly complicated requirements such as the per investor annual investment limit, which could mirror the simpler r... more
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What is CfPA's position on improving the process for Reg CF investors to transfer shares to brokerage accounts after an IPO?
Great question! This relates to CfPA's policy platform. Here is our position on the topic.
When a Reg CF Issuer Goes Public
Investors that have invested in an issuer via Reg CF have difficulty getting their securities into a brokerage account when the issuer conducts an IPO. This sometimes results i... more
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What is CfPA's stance on standardizing the term 'Regulated Investment Crowdfunding' to reduce confusion and enhance industry integrity?
Great question! This relates to CfPA's policy platform. Here is our view on the topic.
Consistency of Terminology
The term “equity crowdfunding” is used frequently by industry participants. This term is misleading because it implies that what investors are getting is an equity investment which is of... more
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What is CfPA's view on increasing FINRA's transparency and consistency in portal regulation
Consistency and Transparency in Oversight of Portals
a. Consistent regulatory compliance is necessary to ensure the viability of the industry. All portals should be subject to the same level of scrutiny and enforcement. Rule violations should be addressed quickly to maintain the public’s confidence ... more -
What is CfPA's view on easing Reg CF financial reporting for early-stage businesses?
Great question! This relates to CfPA's policy platform. Here is our view on the topic.
Reform of Requirements for Financial Reporting
The requirement to provide an independent review or audit is nonsensical for a business with no operating history – we support tailoring the financial reporting requi... more
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What is CfPA's stance on creating a new regulatory tier under Reg CF to simplify requirements for small raises up to $350,000?
Great question! This relates to CfPA's policy platform. Here is our position on the topic.
Exemptive Relief for Small Offerings
Reg CF should be an accessible and useful tool for diverse businesses from small mom-and-pop shops to high-growth tech companies. The current rules make it financially infe... more
