«However, I would like it on the record —
as an expert who has thought about these issues nearly every working
hour over the last four years — that I'm convinced that without the SPV and 12g fixes, retail
investors will be heavily disadvantaged
as compared to
accredited investors and equity crowdfunding will ultimately be seen
as a failure.
As the regulations set forth in Title III are far more burdensome that those in Regulation D offerings for
accredited investors, the SEC has estimated it will require 100
hours of work from professionals, including accountants and lawyers, to comply with the regulations.