On the recordJanuary 10, 2017
Once again, we are seeing an unnecessary, duplicative amendment here. The amendment, as it is laid out, creates a new definition of an issuer. The Securities Exchange Act already defines an issuer, and Ms. Waters' definition is vague, confusing and, frankly, unnecessary. Demo days are opportunities for startup companies to present their ideas to potential investors that are accredited. Again, accredited. At this point, all of America is shouting back at C-SPAN, saying, $300,000 in income per year with $1 million net worth, excluding their home. We get this out there. This is not a solicitation or offering a security. So what I am, quite honestly, concerned about and maybe a little confused about is the point of the HALOS Act trying to fix a problem. It is trying to fix a problem. Remember, we want to expose entrepreneurs and their ideas to the broadest pool of potential investors that includes angel investment community, again, of accredited investors. This requirement raises serious compliance concerns for angel investors. It would require entrepreneurs and startups to perform a compliance function that they may not have the physical or financial means to do so. Again, it is just an additional burden and barrier to entry for entrepreneurs. Again, these are--the entrepreneurs typically aren't the ones that have $300,000 of annual income or $1 million net worth because, frankly, then they wouldn't have to be at the pitch. They could fund it themselves.…





