More on taking the equity crowdfunding cause to individual statesBy http://profile.typepad.com/1237764140s22740 // July 31, 2012 in Crowdfunding
That fellow who is making his rounds on the radio to promote his book on how bloggers manipulate big media and consequently public discourse - I think he is tied up in his own feedback loop.
Case in point #947 on this blog: an email over the weekend from Stanley Florek, CEO of Tangerine Power in Seattle, kindly informing me that the equity crowdfunding movement had a local front before I started covering the McHenry bill.
With the permission of both Stanley and Jenny Kassan (to whose work Paul Spinrad has also pointed us), I am reprinting Stanley's email in this post.
"Mr. Carleton & Mr. Wallin:
"My name is Stanley Florek. I am a Washington entrepreneur and a loyal daily reader of both of your blogs on startup law. Your thread this week proposing a state-level approach to regulation of crowdfunding is something I am pursuing in partnership with my counsel Jenny Kassan at K2 Legal and Cutting Edge Capital. Jenny is at the nexus of locally-based crowfunding in this country using currently available legal frameworks. I wanted to introduce you all directly, in hopes that Jenny’s work and ideas might get better visibility on the increasingly noisy crowdfunding scene. Jenny has been working on the ground-level realities of democratizing capital-raising for several years, and she’ll still be on the scene after the initial hype dissipates over the JOBS act dissipates.
"Among other accomplishments, Jenny’s team at her affiliated nonprofit Sustainable Economies Law Center started the Federal crowdfunding avalache by writing an unsolicited petition to the SEC in 2010 demanding a rulemaking to create a new federal crowdfuding exemption. The project’s modest fee was itself crowdfunded thru the IndieGoGo platform, which was a brilliant stroke of viral marketing. This example demonstrated the thunderous leverage crowdfunding can deliver to an unorthodox idea whose time has come.
"More directly related to your recent post, Jenny drafted a petition to the Washington Department of Financial Institutions with feedback from myself, proposing a variation on the crowdfunding framework Joe proposed. I am attaching the letter she drafted to DFI and the negative response they provided. Perhaps by working together we might address the objections DFI raised, and build momentum towards a crowdfunding framework here that is a model for other states.
"Best regards, Stanley Florek"
Here's a link to that "negative response" from the Washington State securities agency (the DFI) that Stanley references. I think Joe is going to get into dissecting that response. And here's a link to Ms. Kassan's original letter to the DFI.
Photo: ion-bogdan dumitrescu / Flickr.