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SEC Issues Three-Year Research Study on Title III, Regulation Crowdfunding (Reg CF) Fundraising Campaigns

26 Jul

Leading Crowdfunding Industry Analyst Firm, Crowdfund Capital Advisors, States Now is the Time to Update the Regulation to Further Enable Capital Formation

Washington, DC – Recently the Securities and Exchange Commission (SEC) published a staff report on Regulation Crowdfunding (Reg CF), also known as Title III Crowdfunding.

The Commission, in the adopting rules, stated that the “staff will undertake to study and submit a research report to the Commission no later than three years following the effective date of Regulation Crowdfunding on the impact of the regulation on capital formation and investor protection.”

The report finds the size of market, while modest in comparison to the broader financial markets, is evolving and doing so without any material risk to investors. Crowdfund Capital Advisors (CCA) data and analysis were cited in 7 references throughout the report.

“The industry is evolving systematically and responsibly,” says CCA Principal Sherwood Neiss. “With the appropriate adjustments to the regulation we can further enable capital formation without risk to investors. The time is now for the SEC to act.”
Sherwood Neiss, Crowdfunding Capital Advisors, testifies before the SEC

Sherwood Neiss, Crowdfunding Capital Advisors, testifies at the SEC

The CCA data and references used by the SEC were attributed to analysis by CCA and published in VentureBeat as well as Crowdfund Insider. The data comes from CCA’s CCLEAR Database. CCLEAR is the leading Regulation Crowdfunding database that collects, cleans, aggregates and reports on all companies seeking funds via Regulation Crowdfunding as well as those doing parallel 506(c) offerings.

A 506(c) offering is an online accredited investor offering. A parallel offering allows an issuer to run two offerings side-by-side and group the accredited investors in one pool and the Reg CF investors in another. This type of offering is popular for issuers that seek to raise in excess of the $1.07M cap in Regulation Crowdfunding.

Issuers that seek to raise funds via Reg CF must file a Form C (a form filed by a company (issuer) with the SEC before starting to raise capital and discloses financial information for its current and prior fiscal years) as well as a Form C-U (a progress report that an issuer files that discloses total capital raised).

Data that the SEC does not collect in either of these disclosures includes information like industry, a breakdown on the cost of the offering, daily change in capital commitments, daily changes in investors and information on a company’s valuation.

CCLEAR collects all this missing data which allows for more detailed analysis of the market including which industries are most popular with the crowd, which regions of the country have the lowest/highest overall valuations, what industries the crowd is most interested in supporting, etc.

An entire section of the report titled “Cost to issuers of undertaking a crowdfunding offering” came directly from research CCA did with issuers successful with Regulation Crowdfunding.

A key finding from our research, which was highlighted in the report, was that “the total cost of creating a campaign page, issuer disclosures, film, and video, and hiring a marketing firm, a lawyer, and an accountant amounts to approximately 5.3% of the amount raised.”

This average was based on feedback from 81 issuers. “This amount is substantially less than what a typical issuer would incur in a Regulation D offering,” says CCA principal Sherwood Neiss “and is a key reason why more companies should be looking at Reg CF as an attractive pathway to raising funds.”

The report provides a detailed look at how Regulation Crowdfunding has performed through December, 2018. (For people interested in data through today’s date, you can find it on CCLEAR’s Daily Dashboard – see below for the latest data).

“Unlike opponents who said regulated crowdfunding would open the floodgates to fraud, we have yet to see fraud materialize,” says Neiss.

“This is because there are easier ways to defraud investors than to come up with an idea for a business, incorporate it under federal laws, convince a funding portal to list you, spend hundreds of hours and thousands of dollars trying to bring your friends, family and followers to the campaign page, and then hitting 100% of your funding target or the commitments get returned.

Add on top of this the hundreds of discerning eyes picking apart a campaign in the comments section. These types of ‘built-in investor protections don’t exist in other parts of the private capital markets.”

Multiple recommendations were included in the report on how to improve Regulation Crowdfunding. The SEC cited a US treasury Report entitled “A Financial System That Creates Economic Opportunities.”

The Report recommends:

  1. Allowing single-purpose crowdfunding vehicles advised by a registered investment adviser;
  2. Waiving certain crowdfunding offering limits for accredited investors;
  3. Amending certain crowdfunding investment limits by other investors;
  4. Modifying the Exchange Act’s Section 12(g) exemption;
  5. And increasing the limit on how much can be raised through crowdfunding from $1M to $5M.

CCA’s principals were interviewed and cited in the Treasury report. The Fed’s recommendations were a summary of CCA’s more detailed recommendations as requested.

“The industry is evolving systematically and responsibly,” ended Neiss. “With the appropriate adjustments to the regulation we can further enable capital formation without risk to investors. The time is now for the SEC to act.”

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Robert Hoskins, a seasoned Front Page PR veteran provides more than twenty-five years of external communications, media relations, digital social media and SEO skills to Front Page PR’s crowdfunding PR and media relations service portfolio.
Robert Hoskins
(512) 627-6622
@Crowdfunding_PR


Mr. Robert Hoskins is a seasoned marketing veteran with a proven track record of helping entrepreneurs, startups, small businesses as well as Fortune 500 corporations launch successful marketing communications campaigns to gain market traction for a wide variety of products and services.
On a regular basis, Mr. Hoskins consults with crowdfunding campaign managers as well as crowdfunding sites, portals and platforms to deliver successful crowdfunding marketing campaigns.
Google search “Robert Hoskins Crowdfunding PR” to see why Mr. Hoskins is considered one of the industry’s foremost crowdfunding experts that has amassed a huge social media following, which is dedicated to supporting donation-, rewards- and equity-based crowdfunding campaigns.
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Positive Letters Needed to Support the SEC’s Ability to Crowdfunding Pass Title III Guidelines for Small Business

8 Sep

The SEC Claims that It Does Not Have Sufficient Positive Industry Support to Implement Title III Crowdfunding. Let’s Change that Today by Sending in 10,000 Letters and Tweets from American Entrepreneurs and Small Businesses that Want Access to Small Business VC

By Robert Hoskins

Washington, D.C. – I’d like to start off by saying “Hats off” to Justin Ryan and Terell Jones for putting on an awesome Kickercon crowdfunding event in Houston last month. It was, by far, the best crowdfunding conference we have attended to date! All of crowdfunding subject matter experts were there, but this conference did a much better job than most because they addressed where the crowdfunding industry is headed instead of just rehashing the old facts and figures of the JOBS Act.

There were numerous tracks on the Texas Intrastate Crowdfunding Exemption, an excellent Crowdfunding Boot Camp put on by InventIt2Day’s Conley Giles, and great panel discussions on the up and coming real estate crowdfunding industry, but the most important event by far was a presentation by Ron Miller, who has been meeting with numerous officials the SEC in an attempt to try and understand the SEC’s hesitation to implement Title III crowdfunding rules, which are now way overdue.

 

Please Retweet - I suppport Title III Crowdfunding

Please Retweet – We support Title III Crowdfunding to Start Small Businesses!

 

Mr. Miller gave a convincing presentation based on comments from SEC Commissioners and many of its staff members.  The SEC is basically saying that in 560+ pages of public comments, the negative comments outweigh the positive comments supporting the implementation and communicated that if they had a lot more positive support from Americans then they would be more motivated to pass the final guidelines.

In the Crowdfunding Industry we pride ourselves on utilizing the crowd to accomplish many objectives such as raising money for crowdfunding campaigns and helping crowdfunding platforms police potential equity investment deals.

Unlike many established industries, members of the crowdfunding industry have very advanced social media capabilities and very large networks of contacts on Facebook, LinkedIn, Twitter, YouTube and other important social media networks. One of Mr. Miller’s main points was that the crowdfunding industry should begin working together to leverage these social media networks to drum more support.

During the event’s Q&A session, with an after show audience of almost 500 crowdfunding enthusiasts, several comments suggested developing a Title III Crowdfunding Support Form Letter and providing the contact information on where to mail or email these positive Title III Crowdfunding support letters.  Others suggested creating HeadTalker or ThunderClap campaigns.

In addition, the audience and the event hosts suggested contacting your U.S. House of Representatives and U.S. State Senators to let them know that support for Title III Crowdfunding Rules will be an important factor when considering who to vote for this fall.

Please show the SEC your overwhelming support for Title III Crowdfunding and let them know that the general public, entrepreneurs and small businesses are 100% behind creating a Title III equity crowdfunding industry in the United States. Please download a copy of this Form Letter, add your contact information and then send it the SEC. It will take less than 5 minutes, but can make a difference for the crowdfunding industry.

Please repost, retweet and reblog this story.  All copyrights are waived on both the text and the image. Please retweet and republish at will!

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Feel free to mention these handles in your tweets:

 

SEC Chairman Mary Jo White Speech on Evolving with New Financial Challenges in 2014

3 Feb

A Roadmap to New Market Technology, Financial Products, Capital Formation  and Vigorous Enforcement in 2014

41st Annual Securities Regulation Institute Coronado, Calif

February 3, 2014 – For nearly 80 years, the Securities and Exchange Commission has been playing a vital role in the economic strength of our nation. Year after year, the agency has steadfastly sought to protect investors, make it possible for companies of all sizes to raise the funds needed to grow, and to ensure that our markets are operating fairly and efficiently.

The SEC’s 2014 Mission:

But, while commitment to this mission has remained constant and strong over the years, the world in which we operate continuously changes, sometimes dramatically.

When the Commission’s formative statutes were drafted, no one was prepared for today’s market technology or the sheer speed at which trades are now executed. No one dreamed of the complex financial products that are traded today. And, not even science fiction writers would have bet that individuals would so soon communicate instantaneously in so many different ways.

It is because we operate in this vast, fast, and ever-evolving securities market that the Commission, as the regulator of that market, must constantly adapt in order to continue to be effective.

With that in mind, I thought I would speak this morning about some of the transformative changes at the SEC in 2014 and, while doing that, also preview a few of the specific rulemakings and other initiatives that I expect to be on our 2014 agenda.

I. Evolving with Market Technology

While there have been many significant changes since the SEC’s inception, few have had as much impact on our markets as the advances in technology. The manual trades on the exchange floor of the 1930s have given way to trading that is high-tech, high-speed, and widely dispersed among many different venues, some of which did not even exist when I last gave this address, but which now occupy significant parts of the market landscape.

And that landscape changes and evolves further every day.

It is not only our job to keep pace with this rapidly changing environment, but, where possible, also to harness and leverage advances in technology to better carry out our mission.

And, despite significant resource challenges, we are doing precisely that across the agency. Let me give you a few examples.

NEAT

Our Quantitative Analytics Unit in our National Exam Program has, for example, developed a revolutionary new instrument called “NEAT,” which stands for “National Exam Analytics Tool.”

With NEAT, our examiners are able to access and systematically analyze massive amounts of trading data from firms in a fraction of the time it has taken in years past. In one recent exam, our exam team used NEAT to analyze in 36 hours literally 17 million transactions executed by one investment adviser.

Among its many uses, NEAT can search for evidence of potential insider trading by comparing a database of significant corporate activity like mergers against the companies in which a registrant is trading and analyze how the registrant traded at the time of those significant events. NEAT can review all the securities the registrant traded and quickly identify the trading patterns of the registrant for suspicious activity.

In 2014, our examiners will be using the NEAT analytics to identify signs of not only possible insider trading, but also front running, window dressing, improper allocations of investment opportunities, and other kinds of misconduct.

MIDAS

This past year, we also brought on-line another transformative tool that enables us to collect and sift through massive amounts of trading data across markets instantaneously, an exercise that once took the staff weeks or months. We call this technology MIDAS – the Market Information Data Analytics System.

Every day, MIDAS collects one billion records of trading data, time-stamped to the microsecond. Previously, only sophisticated market participants had access to this type and amount of trading data and even fewer were able to process it. At the SEC of 2014, we are aggregating this data and presenting it on our website along with a wide range of analyses. We have made these analyses readily accessible on your computer or even your tablet, with data available in clear, easy-to-read charts and graphs.

MIDAS is already revealing some important, data-based realities that may resolve some of the speculations about behavior in today’s market structure. Just earlier this month, for example, the SEC staff published an analysis showing that for the most part the advent of public transparency for “odd lot” trades does not seem to correspond with a decline in such trades. The staff noted that this result suggests that a lack of transparency may not have been one of the drivers for breaking trades into odd lots, which some observers have suggested is a technique to hide trading activity.

In the coming weeks, we are expecting to post further staff analysis of off-exchange trading, a review of research on high-frequency trading, and a data series on depth-of-book liquidity. I encourage you, after my remarks, to take a look at all of this – right on sec.gov. This is not your father’s SEC – or your mother’s or even your older brother or sister’s. In this rapidly changing environment, we must stay on top of advances in technology. NEAT and MIDAS are important tools that will help us keep pace with evolving technology.

Operational Integrity

Our approach to technology in 2014, however, is not limited to building systems like these for us to keep pace with the evolving technology of the markets. We are also focused on ensuring that the technology used by exchanges and other market participants is deployed and used responsibly in a way that reduces the risk of market disruptions that can harm investors and undermine confidence in the integrity of our markets.

Most recently, following the interruption of trading in Nasdaq-listed securities last August, I met with the leaders of the equities and options exchanges. At my urging, they pledged to work toward enhancing the integrity of market systems, including the critical market infrastructures that can prove to be “single points of failure,” such as public feeds of quotes and trades.

They have since been working hard to develop and implement such measures, and I expect more to be done to address these vulnerabilities in 2014.

In addition, I anticipate that the Commission’s 2014 rulemaking agenda will include consideration of the adoption of Regulation SCI – which stands for Systems Compliance and Integrity. As some of you know, Regulation SCI would put in place new, stricter requirements for the use of technology by exchanges, large alternative trading systems, clearing agencies, and securities information processors. Regulation SCI can be – and should be – the market-side counterpart to the intermediary-focused Market Access Rule adopted by the Commission in 2010 to better regulate how broker-dealers manage the technological and other risks associated with direct access to markets.

II. Evolving with New Financial Products

It is not just technology that has changed over the life of the agency. So too have the financial products that investors, businesses, and other market participants use.

OTC Derivatives

In 1990, for instance, few people would have heard of a credit default swap or any of a number of the other products that make up today’s over-the-counter derivatives market. Yet two decades later, such derivatives comprise a multi-trillion dollar market.

The Dodd-Frank Act directed the SEC – for security-based swaps – and the CFTC – for all other swaps – to create an entirely new regulatory regime for this massive market. Once this regime is fully in place, many over-the-counter derivatives will be traded and cleared on venues accessible by a wide range of market participants, with trade data made readily available to regulators and disseminated to the public. What was once an opaque, bilateral market will largely become a transparent, centrally cleared market.

The Commission has proposed substantially all of the rules required to implement this new regulatory framework. With our proposal for the cross-border application of this framework last year, I expect the Commission in 2014 to move forward with finalizing and implementing these rules.

Money Market Funds

Even when a product is not as new as an over-the-counter derivative, the use of the product may reveal previously unanticipated risks that suggest an evolution in our regulatory approach is warranted. The recent financial crisis provided an unwelcome laboratory for a number of these products.

Money market funds, for example, have for decades been an important part of the financial marketplace. As we saw in the financial crisis, however, they can be exposed to substantially heightened redemptions if investors believe that a fund is about to lose value. The resulting instability in their value can harm investors as well as the entities that turn to money market funds for financing.

In 2010, the SEC took a first step to address this heightened redemption risk by making the funds more resilient. The rule amendments adopted by the Commission in 2010 were designed to reduce the interest rate, credit, and liquidity risks of money market fund portfolios. The Commission said at the time that it would continue to consider whether further, more fundamental changes to money market fund regulation is warranted.

Currently, the Commission is considering two significant proposals for additional reform that were put out for comment last June. One is a floating NAV for prime institutional money market funds – the type of fund that experienced problems during the financial crisis. The other proposal would require money market funds under certain circumstances to impose a liquidity fee and permit the imposition of redemption gates. This proposal is designed to stop a “run” and limit the resulting instability. These proposals could be adopted alone or together.

We have received hundreds of letters on the proposals with a wide range of differing views that we are reviewing closely. Completing these reforms with a final rule is a critical priority for the Commission in the relatively near term of 2014.

Securitization

The financial crisis also revealed how another product – asset-backed securities – could create undue risks to market integrity and investors. Shortly after the financial crisis, the Commission proposed a new set of disclosure rules for asset-backed securities, which have evolved with the Dodd-Frank Act. Finalizing these new disclosure rules remains an important priority for the Commission in 2014.

A related effort is the rules we are required to adopt jointly with several other agencies governing the retention of a specified amount risk by the sponsor of an asset-backed security. We re-proposed those rules late last year, and finalizing them will be a priority for 2014.

III. Evolving with New Paths to Capital Formation

Just as we have seen market technology and products evolve over time, we also have seen massive change in the ease and speed with which information and capital flows. This, in turn, has led companies, investors, Congress, the SEC and others to reconsider how companies can seek capital and communicate with potential investors. Indeed, we are at the start of what promises to be a period of transformative change in capital formation.

In 2013, according to our estimates, capital raised in public offerings totaled $1.3 trillion, as compared to $1.6 trillion raised in offerings not registered with the SEC, with over 65% raised in new and ongoing Rule 506 offerings. So the private offering markets already rival the public markets in terms of capital raised.

And, in 2012, Congress passed the JOBS Act, directing the Commission to implement rules that will have a significant impact on the private offering markets. I know you will be hearing a fair amount about this subject on your panels today, so let me provide just a brief overview of what the SEC will be working on in this space in 2014.

In July, the Commission adopted rules implementing the JOBS Act mandate to lift the ban on general solicitation, and the rules became effective on September 23, 2013. Although existing Rule 506 continues to be a popular method for capital raising, issuers are taking advantage of the new rule. Preliminary information collected by our Division of Economic and Risk Analysis shows that through December 31, approximately 500 offerings were conducted, raising approximately $5.8 billion.

Then, in October and December of last year, the Commission proposed rules to implement the JOBS Act mandates with respect to crowdfunding and Regulation A. While the final framework of these two exemptions is yet to be determined by the Commission, if the enthusiasm for them is any indication, I expect strong interest in raising capital through these mechanisms.

Together, these changes should provide new and expanded ways for companies of all sizes, but particularly smaller companies, to raise capital. The final implementation of crowdfunding and an updated Regulation A is an important priority in 2014, and I expect that the Commission, after thorough consideration of all comments, will move expeditiously to finalize these rules.

These rule changes for the private offering market are just the start of the Commission’s efforts. For the changes demand that the Commission stay focused on the ongoing implementation of the exemptions, what market practices develop, how much capital is being raised, how investors are impacted, and whether fraud or other misconduct is occurring in these markets.

So, staff from across the agency is also set to monitor the developments in the markets following all of these changes. An agency-wide working group has been formed to monitor offering practices and other developments in the Rule 506 market. I have also directed the staff to form similar working groups for both crowdfunding and the new Regulation A.

One key step in the effort to improve our monitoring of Rule 506 offerings will be the adoption of final rules – also proposed in July – relating to amendments to Regulation D, Form D and Rule 156. I know that you have a session later today during which you will discuss these proposed amendments, and I know, from the comment file, what many of you think. We are considering those comments very carefully. Advancing these important rules, after due consideration of the comments we have received, is another important priority for me in 2014.

Disclosure Reform

As we move to complete our rulemaking in the private offering area, it is important for the SEC not to lose focus on the public markets.

I recently spoke about some of my ideas about disclosure reform and in December the staff issued a report mandated by the JOBS Act that gives an overview of Regulation S-K and the staff’s preliminary recommendations as to how to update our disclosure rules. I have asked the staff to begin an active review of our disclosure rules.

We can all probably identify particular disclosure requirements that we might eliminate or modify, but that is not the kind of review and reform I am primarily focused on – and it certainly is not the kind of thoughtful and comprehensive review that I think our disclosure rules demand. I believe we should rethink not only the type of information we ask companies to disclose, but also how that information is presented, where and how that information is disclosed, and how we can take advantage of technology to facilitate investors’ access to information and make it more meaningful to them.

I have asked the staff to seek input from issuers, investors, and other market participants in 2014 as part of this effort, and I encourage all of you to share your views and ideas. The ultimate objective is for the Commission to improve the disclosure regime for the benefit of both companies and investors.

IV. Vigorous Enforcement in 2014

The agency’s evolution in response to a rapidly changing market is not confined to rulemaking or market oversight. We have also found it necessary to adapt our policies, priorities, and approach with respect to enforcement as well. And no discussion of the SEC in 2014 would be complete without my touching on some of these changes and giving you some idea of what to expect this year. The coming year promises to be an incredibly active year in enforcement, as we continue to vigorously pursue wrongdoers and bring enforcement actions across the entire industry spectrum.

Admissions

As you know, for many years, the SEC, like virtually every other civil law enforcement agency, typically did not require entities or individuals to admit wrongdoing in order to enter into a settlement. This no admit/no deny settlement protocol makes a great deal of sense and has served the public interest very well. More and quicker settlements generally mean that investors receive as much (and sometimes more) compensation than they would after a successful trial – and without the litigation risk or the inevitable delay that comes with every trial. Settlements also can achieve more certain and swifter civil penalties, and bars of wrongdoers from the industry or from serving as officers or directors of public companies – all very important remedies for deterrence and the public interest.

So, why modify the no admit/no deny protocol at all? It is not a new question and one that many of you continue to ask. Even before my arrival as Chair, the Enforcement Division decided to require admissions where parallel criminal or other regulatory cases were brought with admissions. Why? Because admissions can achieve a greater measure of public accountability, which can be important to the public’s confidence in the strength and credibility of law enforcement and the safety of our markets. It is not surprising that there has also been renewed public and media focus on the accountability that comes with admissions following the financial crisis, where so many lost so much.

And it should be no surprise that my views on admissions were formed long before recent events and were shaped by my time as United States Attorney. In the criminal realm, guilty pleas are accompanied by admissions of guilt, which eliminate any doubt about the conduct of the defendant and provide additional accountability for the crime.

As United States Attorney, I made the decision that companies should, in certain circumstances, admit their wrongdoing, even if they were not criminally charged, but where there was a special need for public accountability and acceptance of responsibility. That is why, when I negotiated the first deferred prosecution for a company, back in 1994, I required an admission of wrongdoing, and I brought that mindset to the SEC when I became Chair last April.

After studying and discussing the issue with the staff and my fellow Commissioners, I decided to modify the SEC’s protocol to demand admissions in an expanded category of settlements. That change occurred in June and you have begun to see it play out in a number of cases. When we first announced the change in approach, we outlined broad parameters of the types of cases in which we will consider requiring admissions as part of any settlement. And now, we have a number of cases with admissions that illuminate those categories.

So, for example, we have said we will consider admissions in cases involving egregious conduct, where large numbers of investors were harmed, where the markets or investors were placed at significant risk, where the wrongdoer poses a particular future threat to investors or the markets, or where the defendant engaged in unlawful obstruction of the Commission’s processes. Just last month, we required three brokerage subsidiaries to admit to a scheme in which they repeatedly deceived their customers about their compensation on securities transactions – and in some cases even provided falsified trading data to their customers in an effort to avoid detection. The conduct was egregious and harmed many investors, thereby justifying admissions.

Similarly, we demanded that a bank admit that its internal controls were deficient in failing to detect and prevent, and then disclose to its board and investors, massive losses by some of its traders, thereby putting millions of shareholders at risk and resulting in inaccurate public filings.

To be sure there was no ambiguity about the misconduct of a defendant who was continuing to deal with investors, we required a hedge fund adviser to not only agree to a bar from the securities industry for five years, but to also admit to misuse of more than one hundred million dollars of fund assets in order to pay his personal taxes through a personal loan that was not timely disclosed to investors.

As we go forward in 2014, you will see more cases involving admissions. When and how we decide to require admissions will continue to evolve and be subject to further articulation in the cases we bring and as we discuss it publicly.

Financial Fraud

This year will likely see us complete our docket of major investigations stemming from the financial crisis. As we do, our focus and resources will naturally turn to other priorities. This shift has already begun.

Last fall, the Enforcement Division formed a Financial Reporting and Audit Task Force. This dedicated group has very talented accountants and attorneys who will broaden and thereby improve the way we look at financial reporting misconduct.

The Task Force is pursuing a number of goals, including building a deep understanding of the state of financial reporting fraud – not just why it happens, because there is plenty of learning on that question, but how it happens and in what specific areas.

As you would expect, we look closely at the auditors in every financial reporting case, but we are also closely focusing on senior executives for possible misconduct warranting charges. The message is that critical accounting issues are the responsibility of all those involved in the preparation and review of financial disclosures.

Market Integrity

As I have discussed, technology has worked a fundamental shift in the way securities are priced and traded – a shift that has only accelerated in the past several years. In the last two years, we have tried to send a strong enforcement message to the exchanges and alternative trading systems that play critical roles in securities market transactions that they must operate fairly, within the rules and with a close eye on their responsibilities to safeguard their technology. Cases have been brought against an exchange that inadequately tested its IPO systems and was therefore unable to handle a highly anticipated IPO and then did not follow its own rules in the aftermath; against a different exchange for compliance failures that gave certain customers an improper head start on trading information; and against a dark pool for failing to protect the confidential trading information of its subscribers. When technology presents new opportunities for innovation, changes must be deployed responsibly, after careful testing, and within the rules and parameters of the trading environment. Market structure integrity actions will remain a priority in 2014.

As you will hear when Andrew Ceresney, our Director of Enforcement speaks to you over the coming days, there are many other enforcement priorities for 2014 that you should be aware of. These include, but are by no means limited to, FCPA, insider trading, and microcap fraud. It will, in short, be a very busy year in enforcement.

Conclusion

I hope I have given you a sense of some of the things we will be doing in 2014 and a flavor for how dramatically and vibrantly things have changed at the SEC as our world and markets have changed. There is more, of course, we will be doing and considering in the coming year, both on our own initiative and as required by the Dodd-Frank and JOBS Acts – equity market structure, duties of brokers-dealers and investment advisers, the management and responsibilities of clearing agencies and credit rating agencies, Dodd-Frank executive compensation rulemaking, target date funds, systemic risk issues, broker-dealer financial responsibility, and more.

It is a constant, but always exciting, challenge to keep pace and indeed to accurately see around the next corner for the newest market developments or another innovative variant of, or new venue for, fraud. I now am privileged to have an up-close and personal role in all of this. And it is my strong conviction that the women and men of the SEC are, as has always been true, more than up to these challenges. As Alan Levenson said in January 2003, almost eleven years to the day when he spoke about the strength of the SEC: “It was the creativity of the staff… [they] had a drive and a genuine interest in protecting investors and the public interest….” The challenges and tools change, but creativity, drive, and commitment to the mission continue unchanged at the SEC in 2014. Alan Levenson, I think, would be very proud.

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ByOwner.com Crowdfunding Advertising Portal Fights Fraud and Crime With New Social Graphing Tool from Facebook

9 Dec

The nationwide classified advertising site uses  Social Graphing technology from social media networks such as Facebook.com to protect free Crowdfunding campaign advertisements

By Robert Hoskins

Here is a good example of how Crowdfunding platforms should be using social graphing technology from social networks like Facebook.com to let investors/donors research their campaign managers to see who they are and what type of friends, photos and interests they have listed on their Facebook profiles.

ByOwner.com eCommerce Portal Fights Crime With New Social Graphing Tool to Build Safer Classified Ads to promote Crowdfunding campaigns

ByOwner.com eCommerce portal fights crime with new social graphing tool to build safer classified ads to promote crowdfunding campaigns

Most people who launch Crowdfunding campaigns do not consider advertising as a way to increase their reach, but using free classified advertising platforms like ByOwner.com, crowdfunding campaign managers can place ads in a wide variety of places to increase their crowdfunding profile’s traffic during the bottom of the “U” or lull that many campaigns experience during the middle of their campaign.

Crowdfunding platforms should note how ByOwner.com is combating the growing crime wave associated with placing online classified advertisements, by deploying a new four-step verification process that utilizes a sophisticated social graphing tool that offers buyers/sellers a more transparent process to research and complete safer classified advertising sales transactions. The same technology should be used on every Crowdfunding intermediary to let donors/investors cross tab their personal networks on social media sites such as Facebook, Google+, Linkedin and Twitter to see what contacts their social networks have in common.

ByOwner.com uses the social graph from Facebook’s API to showcase relationships between users. The social graph is a digital map of both party’s friends and how they relate to one another. It integrates information from each user’s profiles giving buyers a sense of confidence with whom they are purchasing from, and sellers will have transparency of who is their buyer.

When buyers and sellers have overlapping networks, ByOwner.com automatically displays people that appear in both people’s networks. Users can then verify a person’s identity or at a minimum get a sense of the person they are dealing with by reviewing their friends, photos, and other interests that are highlighted on their Facebook pages.

“As we’ve been building our classified advertisement posting portal, we set Google alerts to monitor news stories posted about Backpage.com, Craiglist.com and others,” said Greg Sullivan, ByOwner.com’s CEO. “The number of crime related stories we discovered was astounding from people who were robbed at gun point, raped or murdered because of a classified ad they listed or responded too.”

“If these customers had used ByOwner.com’s social graphing technology to review the each other’s profiles before their meeting, they could have avoided questionable individuals,” Sullivan continued. “Our new social graph verification system makes it easier to track and eliminate people who are posting ads for fake DNA tests, positive pregnancy tests or participating in human trafficking, prostitution, scams and other types of fraudulent or illegal activities.”

As the Christmas and holiday seasons approach, ByOwner.com offers a safe place to post classified ads to buy, sell and shop for great deals on affordable iPhones, iPads, Xboxs, Play Station 4s, cars/trucks for salehomes for salerooms for rentvacation rentals and post free job listings.

ByOwner.com is a classified advertisement posting community based in Florida that offers homes for sale, vacation rentals, apartments for rent, autos, jobs, and more than 91 different categories of products and services. Customers can place their advertisement for free or place premium advertisements on the ecommerce portal to attract buyers worldwide and is 100% free to use. Third-party classified advertising sites are welcome to upload their inventory for free to increase their customer’s exposure. Visit www.byowner.com for more information.

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Mary Jo White Senate Hearing Testimony Lists JOBS Act Crowdfunding Rules as 1st on SEC Agenda

11 Mar

Testimony of Mary Jo White

Nominee for Chair of the U.S. Securities and Exchange Commission

Before the United States Senate Committee on

Banking, Housing, and Urban Affairs

March 12, 2013

Chairman Johnson, Ranking Member Crapo, and Members of the Committee:

It is my privilege to appear before you today as President Obama’s nominee to be the thirty-first Chair of the Securities and Exchange Commission.

Mary Jo White Confirmation Hearing Chair of the U.S. Securities and Exchange Commission Before the United States Senate Committee on Banking, Housing, and Urban Affairs

Mary Jo White Confirmation Hearing Chair of the U.S. Securities and Exchange Commission Before the United States Senate Committee on Banking, Housing, and Urban Affairs

There is no higher calling than public service. As the United States Attorney for the Southern District of New York for almost nine years, I worked very hard on behalf of the American people investigating, prosecuting, and punishing those who committed crimes. From white collar criminals to terrorists – regardless of the complexity of the case or the identity of the defendant – we always strove to do the right thing and to vigorously enforce the law. Today, I am honored by the prospect of potentially returning to public service as the Chair of the SEC to help carry out its essential mission.

While I served as United States Attorney, our office worked closely with the SEC investigating and prosecuting violations of the federal securities laws by both companies and individuals. Through that experience, I became a strong admirer of the expertise, independence, and commitment of the Commission and its staff. I fully appreciate the critical role the SEC plays as the primary regulator of our capital markets and as a strong advocate on behalf of investors. Today, in the wake of the financial crisis and in the midst of implementing the substantial legislative mandates of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and the Jumpstart Our Business Startups Act (JOBS Act), the SEC’s importance and scope of responsibilities are greater than ever.

If confirmed, I will vigorously embrace and carry out the SEC’s mission to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. The SEC’s mission has a tri-partite mandate, but the component parts should not be viewed as in conflict with each other. It is the responsibility of the Chair and the Commission to take the long-term view, balance the objectives when necessary, and seek to fulfill all parts of its critical mission. Then, our markets can thrive and investors will be protected and benefit.

As was true when Chairman Schapiro was first before this Committee in 2009, this too is a crucial time for the SEC. Although the worst of the recent financial crisis may be behind us, none of us can be complacent – least of all the SEC, which has faced a number of its own challenges. Under the leadership of Chairman Schapiro and Chairman Walter, the SEC has made significant strides to strengthen its examination and enforcement functions, improve its capacity to assess risks, and enhance its technology.

Our markets, however, are continuously evolving, and the technology of today is most certainly not the technology of tomorrow. Fast-paced and constantly changing markets require constant monitoring and analysis, and when issues are identified, the investing public deserves appropriate and timely regulatory and enforcement responses.

I am acutely aware that the position of Chair of the SEC carries with it heavy responsibilities and many challenges. But I commit to this Committee and the American public that, if confirmed, I will work tirelessly and do everything in my power to effectively lead the SEC in fulfilling its mission. Let me very briefly highlight a few early priorities were I to be confirmed.

First, I would work with the staff and my fellow Commissioners to finish, in as timely and smart a way as possible, the rulemaking mandates contained in the Dodd-Frank Act and JOBS Act. The SEC needs to get the rules right, but it also needs to get them done. To complete these legislative mandates expeditiously must be an immediate imperative for the SEC.

With respect to rulemaking, rigorous economic analysis is important and should inform and guide the decisions that are made. Although challenging – particularly in the quantification of benefits – in my view, the SEC should seek to assess, from the outset, the economic impacts of its contemplated rulemaking. Such transparent and robust analysis, including consideration of the costs and benefits, will help ensure that effective and optimal solutions are achieved without unnecessary burdens or competitive harm. If confirmed, I would continue the efforts of the Commission to ensure that the SEC  performs robust analysis in connection with its rules and in a manner that does not undermine the SEC’s ability to carry out its mandate to protect investors and our capital markets.

Second, if confirmed, it will be a high priority throughout my tenure to further strengthen the enforcement function of the SEC – it must be fair, but it also must be bold and unrelenting. Investors and all market participants need to know that the playing field of our markets is level and that all wrongdoers – individual and institutional, of whatever position or size – will be aggressively and successfully pursued by the SEC. Strong enforcement is necessary for investor confidence and is essential to the integrity of our financial markets. Proceeding aggressively against wrongdoers is not only the right thing to do, but it also will serve to deter the sharp and unlawful practices of others who must be made to think twice – and stop in their tracks – rather than risk discovery, pursuit, and punishment by the SEC.

Third, the SEC needs to be in a position to fully understand all aspects of today’s high-speed, high-tech, and dispersed marketplace so that it can be wisely and optimally regulated, which means without undue cost and without undermining its vitality. High frequency trading, complex trading algorithms, dark pools, and intricate new order types raise many questions and concerns. Are they problematic for retail and non-institutional investors? Do they result in unnecessary volatility, or create an uneven playing field? Or do these modern-day features bring benefits such as efficiency, price reduction, and healthy competition to our markets? Do they do all of these things? The experts and studies to date have not been consistent or definitive in their observations and findings about whether and to what extent harm is caused by the current market structure and practices. There must be a sense of urgency brought to addressing these issues to understand their impact on investors and the quality of our markets so that the appropriate regulatory responses can be made. If confirmed, I will work not only to ensure that the SEC has the cutting-edge technology and expertise necessary to enable it to keep pace with the markets and its responsibilities to monitor, regulate, and enforce the securities laws, but also to see around the corner and anticipate issues.

There are, of course, many other important areas within the jurisdiction of the Commission: from money market funds to private fund advisers, from credit rating agencies to clearing agencies, from the appropriate standards and regulations governing the conduct of broker-dealers and investment advisers when providing investment advice to retail customers to how to make public issuer disclosures more meaningful and understandable to investors, to name just a few. If confirmed, I would focus on these and the many other challenges facing the SEC.

In conclusion, it would be my privilege and honor to work with the men and women of the Commission and this Committee to help carry out the SEC’s mission. Thank you for considering me to serve in this capacity and for the opportunity to appear before you today. I would be happy to answer your questions.

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Injecting Credibility and Accountability into the Equity Crowdfunding Industry

7 Feb

How a Crowdfunding Audit Bureau Could Give the Crowdfunding Industry Instant Transparency

By Robert HoskinsCrowdfunding Press Center

While most of the Crowdfunding industry is waiting to see what type of guidelines the Securities Exchange Commission (SEC) will issue for Title II, Reg. D accredited investors, it would be a good time for the Crowdfunding industry to start discussing a list of recommended solutions that would make it easier for the SEC to roll out some proposed rules for Title III unaccredited investors.

The Crowdfunding industry needs to start sharing their thoughts on exactly what hurdles are preventing the SEC from issuing the Crowdfunding guidelines in the news media so that everyone in the industry can put their heads together and come up with a creative solution that will make everyone happy.

The average American has no idea how to look up items placed on a Government docket, much less get involved in filing public comments with the SEC to help steer the public policy decisions that will be made soon for the Crowdfunding industry. One thing that would be helpful in bringing the general public up to speed on Crowdfunding is to begin holding open meetings that include journalists, industry analysts and industry experts from other industries that have well established sales, distribution and venture capital investment channels.

There are many venture capitalists and angel investors that have been working in the high-technology industries such as security, application development, data mining, data warehousing, wireless mobility and social networking channels that would make great speakers for these events and could provide a wealth of information that would benefit up and coming Crowdfunding Service Providers (CSPs).  Not only would these types of events be good for networking, but they would generate lots of positive news coverage.

The more informative new articles that are shared via mass media outlets, the quicker the momentum will begin to  pick up for the Crowdfunding industry.  The Crowdfunding industry really needs to work closer with experts in the information technology and computer networking hardware industries to start publicizing how various flavors of technology can be harnessed to resolve many of the industry’s concerns.

For example, most people, including the media, seem to think that the SEC is extremely worried about the opportunity for fraudsters, but in reality, they are probably a lot more worried about how much money and how many employees they will need to police 10,000 Crowdfunding portals.  Or how will they regulate the 226 million potential investors that are 18 years or older in the United States that are only allowed to donate a maximum of $2,000 per year to Equity Crowdfunding platforms?

Some great ideas that have already popped up on the radar screen for consideration include crowdfunding credit checks, credit bureaus and accreditation credentials.  The problem is that most of the technical details for how these ancillary businesses will conduct their operations has not been made public or talked about in the industry trade press. Portals and eCommerce centers have been around for a long time and the technology to automate and ensure security is very mature.

Another tool  that has not been talked about yet, but has served as a very useful role in the advertising industry might include establishing a Crowdfunding Audit Bureau that audits a Crowdfunding Intermediary’s subscribers.  Audit statements have been used by print media buyers for decades to determine whether or not a publication was worth investing $25,000 to buy an advertisement to reach a specified target audience of potential buyers. Why not audit a Crowdfunding intermediary’s investors?

Audit statements served as a very useful tool because they broke down the publication’s subscriber’s demographics and presented the information in a standardized format that made it very easy to compare one publication’s subscribers versus all of their competitors on an apples to apples comparison. Crowdfunding Audit Statements would hold Crowdfunding sites and their investors accountable for the integrity of their data and put the burden of monitoring 10,000 Crowdfunding industry portals on a non-profit organization, not the SEC.

Using Crowdfunding Audit Rules each intermediary would publish a Crowdfunding Audit Statement, which is then audited by a non-profit, third-party vendor.  This process would make it fairly easy to keep track of the industry and its players. Audit statements would allow new intermediaries and the SEC to analyze in great detail what type of investors and investments each portal was generating by looking at the demographic, psychographic and financial characteristics reported for its subscriber base via the audits.

There are several auditing organizations that have been around for many years such as the Alliance for Audited Media or Business Publications Audits (BPA) Worldwide that were originally setup to audit statements from newspapers and magazines so that advertising agencies could analyze that value of a publication’s target audience before investing millions of dollars to advertise to reach their respective readers.

Audit statements were not required by the government, but they served a very useful purpose. Without an audit statement a media buyer always knew immediately that buying advertising in that publication would not be worth the risk. So why not implement a Crowdfunding audit system what that would allow investors and Crowdfunding campaign managers to select Crowdfunding intermediaries based on their audit statements?

Using qualification forms similar to old-school business reply cards, all Crowdfunding intermediary members should be required to fill out in-depth qualification forms that ask many questions related to what type of investor they are, what types of investments they are seeking and how much investment capital they are authorized to make during a given calendar year.  Other questions could probe into what type of company they work for, what vertical business segments they have experience with,  their job function and title,  yearly salaries, etc.  Call centers using data warehouses and financial data mining techniques could then verify the validity of this information.

Crowdfunding sites like Kickstarter are already doing a good job at reporting what industry segments are using their sites, what industries are receiving the largest Crowdfunding donations, as well as what industries have the highest success rates, but they really don’t provide much information on the pool of Crowdfunding donors/investors their site retains. With Kickstarter this is not really an issue, but for the hundreds of smaller Crowdfunding sites knowing for sure what pool of donors/investors they have in their subscriber databases would be great information to have in order to make a wise Crowdfunding campaign decision.

In addition, audit statements should go into great detail about how a Crowdfunding site generates their investor base.  Did investors sign up because the site is a leading Crowdfunding platform, or did the site offer them a free tablet to join their ranks?  A site with 20,000 serious investors that are there to invest will provide a much better return-on-investment than a site with 1,000,000 amateur investors that only signed up to get a free prize.

Among other things this process would shine a light on the rise and fall of registered investors per site, the platform’s success rate for Crowdfunding campaigns as well the growth rate by industry, average investment size and percentage of accredited investors versus unaccredited investors.  Perhaps Crowdfunding intermediaries should be required to exceed a 50-percent or better success rate for their campaigns by providing Business Partner Programs to provide professional assistance and improve investment performance ratios.

Using an audit statement process also would make it easy to educate investors and Crowdfunders to always ask Crowdfunding intermediaries for their Crowdfunding Audit Statement in a similar manner to how car buyers have been trained by the media to request a CarFax before buying a used car. Not having a CrowdFax Audit Statement would be a very easy way for inexperienced investors and Crowdfunding campaign managers to recognize sub-standard Crowdfunding platforms.

Everyone seems to have a general consensus that Crowdfunding will be extremely beneficial for the America economy because it will provide startup capital to millions of new and existing businesses where none has been available for the last five years. So it would be in the Crowdfunding industry’s best interest to do a better job at publishing whitepapers and industry research reports that detail how leading technology and standard operating procedures can be used effectively to protect all entities from fraud.  Instead of blaming the SEC for moving slowly, we should make their job easier by recommending relaxed, but fair rules that facilitate the ability for 98% more Americans to start investing in our future by placing well-thought-out Crowdfunding investments and receiving a good return-on-investment.

Crowdfunding CEO Predicts Industry Shakeout in 2013

22 Jan

By Robert Hoskins

We agree with the CrowdFunding Incubator that there is a growing misconception that if you just toss an idea up on a crowdfunding website, money will come running after it. Or the belief that contributors stay up all night scouring the internet for projects they can toss extra money at. This grandiose belief in monetary magnetism is going to cause a lot of crowdfunding project sponsors incredible grief in 2013. The fact is that any venture requires a vigorous and continuous participation on the part of sponsors in promotion. Project sponsors will have to put more of their resources into promotion and building credibility, and this will translate to an improved standard of quality in this new capital market medium.

What's in it for the Contributors?

The Crowdfunding Proposition

“When the credit card bills from Christmas come rolling in, and when some crowdfunding platforms and sites start to post their actual success and failure numbers, prospective contributors are going to be tougher to come by. They will be more cautious, more skeptical and have less money to gamble with than in 2012,” says Douglas E. Castle, the CEO of CrowdFunding Incubator, LLC (CFI), looking ahead to an inevitable shakeup in the crowdfunding industry.

Castle continued by saying, “If anything, entrepreneurs are going to have to do everything that they can to convince an increasingly disenchanted public that their projects will not turn out to be embarrassments, and to persuade the public that contributors, as true believers, will receive some form of compensation, either real or emotional, in exchange for their paid vote of confidence.

The notion of just posting up a request for funding on the web and waiting for the money to materialize is disappearing. Now, more than ever since the crowdfunding phenomenon started gaining media traction and public attention two years ago, organizations which require crowdfunding for their capitalization base are going to have to participate actively in the promotion of their ideas.

This will include more than ever a great deal of blogging, classified advertising, emailing, text message announcements, press releases, videos and social media activity And while that doesn’t have to be expensive, the small sums and significant hours required to get the news of a project to stand out and reverberate are going to be a requirement. Sponsors who are truly ambitious about raising money through this supercharged vehicle will have to drive much of their own traffic to the crowdfunding sites or platforms where they are being featured.”

CFI’s Chief Operations Officer, RD Watkins added, “The better crowdfunding websites are going to be getting more choosy about which project promoters they want to rent out their valuable website real estate to. The decision makers who own these crowdfunding platforms are going to be looking very, very carefully at not only the viability of any given project, but they’ll also be looking at how much the project’s sponsors are willing to participate in the promotional process.

Money is not getting easier. It is getting harder and will probably continue along that trend for some time to come. The whole process is becoming much more active and participatory than before; especially in light of some recent refunds to contributors and some funded but badly stalled projects.”

Castle added, “People are getting educated about crowdfunding. Contributors as well as the operators of the funding sites want to see three things. They want an idea or a business plan that makes sense; they want some kind of consideration in exchange for their contributions of seed or early-stage capital; and they want to see that the innovators and entrepreneurs who are looking to them for funds have some serious skin and sweat in the game.

“Projects just don’t fund themselves. In the coming year, the entrepreneurs are going to have to do everything within their power in order to drive prospective contributors to the platforms where their businesses or business ideas are being showcased.

“On an optimistic note, this market scenario will impose a higher standard of quality on the part of both the website owners and the entrepreneurial hopefuls. It’s an inevitable form of ‘market adjustment’ or ‘correction’ that follows a period of too much money and too little oversight. This will benefit the contributors and the private sector. It will be refreshing to see some sensibility and sanity brought home to the crowdfunding market.”

Front Page PR Rolls Out Crowdfunding PR Service for Crowdfunders Who Want to Launch Successful IndieGoGo, Kickstarter or RocketHub PR Campaigns; Opens Crowdfunding Press Center

15 Jan

Crowdfunding Services Advise Entrepreneurs, Small Businesses and Inventors on How to Prepare Profiles With SEO, Public Relations, Media Training, Media Relations and Social Networking in Mind

AUSTIN, TX–(Marketwire – Jan 15, 2013) – Front Page PR, the industry’s #1 crowdfunding PR firm, rolled out a new “Crowdfunding Press Center” (https://crowdfundingpr.wordpress.com) to help reporters, industry analysts as well as entrepreneurs, small businesses and accredited investors get acclimated to the new equity crowdfunding industry which is about to skyrocket in the United States.

Regardless of whether clients want to raise money successfully using donation-, lending-, perks-, rewards- or equity-based crowdfunding portals, Front Page PR can advise clients on how to build crowdfunding profiles, shoot introductory videos, provide attractive rewards and perks, schedule event and email marketing campaigns to boost the middle of the campaign lull as well as setup campaign fulfillment houses to ensure rapid crowdfunding campaign fulfillment after the deal is done.

“Beginning Crowdfunders usually have a limited marketing budget, which is one of the reasons they turn to Crowdfunding to help them raise enough money to pursue their dreams and bring their creative ideas to fruition,” said Robert Hoskins, Front Page PR’s Director of Media Relations. “Instead of paying $10,000 to $20,000 to hire a cost-prohibitive PR firm, our team of media professionals will share our expertise, PR templates, strategies, databases and media pitching secrets, which have generated more than $30 million worth of positive publicity for our clients over the past 20 years.”

Many people think that securing positive stories in the press necessitates a miracle, but in reality it is really just a simple process of understanding what the media needs to do their job. The media is always searching for a great story that teaches their readers something important.

The crowdfunding industry is expected to grow rapidly into a $300 billion investment industry. Front Page PR is currently seeking seasoned marketing professionals to fill PR, media relations, investor relations, social media networking and digital content management roles to help us scale to meet the skyrocketing market demand for professional crowdfunding marketing and PR experts. Forward resumes to the email below.

In addition, we provide white-labeled marketing programs for all crowdfunding portals that want to increase their platform client’s crowdfunding success rate.

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Contact:

Robert Hoskins
Front Page PR
East Coast: (512) 627-6622
West Coast: (602) 326-0940
rhoskins[at]frontpagepr.com

Crowdfund Texas Press Conference

9 Jan

On Tuesday, January 8, 2013, all of the Crowdfunding pioneers meet with several hundred Crowdfunding advocates to get the inside scoop on when the Equity Crowdfunding industry will become a reality in the United States.

 

 

Fraud: Enough with the Rhetoric – Investment Crowdfunding Works. Here’s the Proof

5 Jan

A polluted rhetoric on Crowdfunding has tried emerge. It asserts that investment crowdfunding will be a cesspool of fraud, certain to bamboozle layman investors out of their hard-earned money. It proclaims crowdfunding represents a grave threat to investors, set to open a “floodgate of fraud.”  But it completely ignores the data; completely disregards the truth. The truth is: investment crowdfunding works. And using data, Jonathan Sandlund, The Cafe Crowd proves it with data from the UK’s very successful equity crowdfunding portals.

Read more…

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