Founder of Wales Capital, a business strategy and regulatory compliance consulting firm and CFIRA Executive Board Member Kim Wales’ submitted comment letters to the Securities and Exchange Commission on the proposed rules for Rule 501, “Accredited Investor Definition”, Rule 147, a new exemption in addition to modernization of the existing rule and Rule 504 which increases the offering limitation to $10 million. Ms. Wales commended the Commission “for responding to changes in state regulation and capital formation practices in a pro-active and forward thinking manner.” What is critical to stimulating the economy and getting early stage and emerging growth companies the money needed to grow and sustain themselves through capital raising options which can and will be significantly broadened, with no loss of investor protection, if the proposed revisions [incorporating CFIRA’s comments of course] are adopted.
The balance of the letters, outlines CFIRA’s support of multiple specific proposed changes to Rule 147 and Rule 504 and the the letters provided further alternative recommendations to expand the current proposals. As related to the Accredited Investor Definition, Kim Wales, DJ Paul and Chris Tyrrell, some of CFIRA’s leadership co-authored the letter to Commission in August 2014, in which many of their recommendations we incorporated into the proposal released in December 2015. Ms. Wales wrote a cover letter to Chair, Mary Jo White and resubmitted the original letter for further consideration.
Indeed, the proposed changes to Rule 147 and Rule 504 will be a game changer for entrepreneurs and small business looking for capital. They take a lot of the complexity out of, and add significant clarity to, the existing rules making them a much more viable and useful option for capital raisers.