Lobbying group for venture capital firms weighs in on proposed changes to Reg DBy http://profile.typepad.com/1237764140s22740 // October 21, 2013 in JOBS Act, Reg D, VCs
This is interesting: the National Venture Capital Association, or NVCA, filed a comment letter with the SEC on the Commission's proposed rules to overhaul Form D.
Typically, this lobbying arm of the venture capital industry sits out policy matters, legislation, and rule changes that impact angels and entrepreneurs seeking seed financing.
For instance, during Dodd-Frank, back in 2010, the NVCA sat out the attack on angel financing and let angels fend for themselves in persuading Congress that it did no good for America's innovation economy to effectively push two thirds of eligible Americans out of the accredited investor category. (The NVCA's policy priority at that time? Taxation of carried interest.)
And when it came to the JOBS Act, venture capital's lobbyists pushed for the IPO on-ramp and the raising of the number of shareholders a private company could have. Title II reforms - i.e., Lifting the ban on general solicitation and adding an angel platform exemption to federal broker-dealer registration requirements - those again were issues left to angels, as far as advocacy from the startup financing ecosystem was concerned.
To my knowledge, the NVCA sat out the opportunity to comment on the general solicitation rule, establishing new Rule 506(c), before it became final on September 23.
The letter is dated September 23, so I assume it is been on the SEC site for some weeks now. I only noticed it yesterday through a tweet from Joe Wallin.
Time permitting, I'll read through it this week and let you know what I think.
Photo: Brother O-Mara / Flickr.