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REISA Submits Comments to SEC Regarding the Proposed Rulemaking in Connection with Revisions to Regulation A

Mar 25, 2014

REISA’s Legislative & Regulatory Drafting Task Force has submitted a letter in response to the SEC’s request for comments to the proposed rulemaking in connections with revisions to Regulation A, promulgated under Section 3(b) of the Securities Act of 1933, as amended (the Securities Act), as encapsulated in Title IV of the JOBS Act. REISA’s comments are focused on these issues: State Preemption, Limitation on Types of Issuers Able to Use Regulation A, 10% Cap on Investments in Tier 2 Offerings, and Application of Rule 15c2-11 of the Exchange Act and Rule 144 of the Securities Act.
 
REISA believes in the importance of improving access to capital and spurring economic growth. However, it also recognizes the importance of balance between investor protection and capital formation. REISA strongly believes that the SEC has substantially achieved that balance, especially in connection with state preemption, the 10% Cap and Rule 15c2-11 and Rule 144.
 
REISA’s Legislative & Regulatory Drafting Task Force is comprised of Deborah Froling, Arent Fox; John Grady, National Fund Advisors; Tom Voekler, Kaplan  Voekler Cunningham & Frank; and Darryl Steinhause, DLA Piper. The comment letter was signed by REISA President Mark Kosanke, Concorde Investment Services.
 
Read the full comment letter here.