CfIRA Weighs in on House Oversight Committee Meetings Examining the SEC’s Failure to Implement the JOBS Act and its Impact on Economic Growth

As leading advocates in the fight to democratize access to capital, CfIRA members have submitted the following letter to McHenry, Fitzpatrick and the members of the Oversight Committee who are listed as CC’s at the bottom of the letter. We are at a critical time in the regulatory process; as we have seen in the past with legislation such as Dodd-Frank, important changes to our laws can be stalled or killed because of the agendas of a few people at the top. With the anniversary of the JOBS Act fresh in our minds and the confirmation of Mary Jo White as the 31st Chairwoman of the SEC, we are at a perfect time to act. Below is a letter that was sent last week to the House Subcommittee—we invite you to join with us and call your members of Congress; ask them to attend this important Subcommittee hearing. More details can be found here:

House Subcommittee to Hold Hearing–Examining the SEC’s Failure to Implement Title II of the JOBS Act and its Impact on Economic Growth


Crowdfund Intermediary Regulatory Advocates

300 West 49th Street, Unit 200

New York, NY 10011


April 16, 2013


House Committee on Financial Services

Subcommittee on Oversight and Investigations

2129 Rayburn House Office Building


Washington, DC 20515


RE:  Hearing entitled “Examining the SEC’s Failure to Implement the JOBS Act and its Impact on Economic Growth”

We represent the Crowdfund Intermediary Regulatory Advocates (CfIRA), a coalition of industry professionals representing funding portals intermediaries, entrepreneur issuers, investors and third party service providers for the anticipated securities based crowdfunding (“crowdfund investing”) industry.  Created in April, 2012, as a result of the Jumpstart Our Business Startups (JOBS) Act, our organization has met with leadership among the Securities and Exchange Commission staff and leadership among FINRA on a number of occasions.  Resulting from these meetings, we have also submitted approximately fifteen comment letters outlining the industry’s response to anticipated changes in Title II and Title III of the Securities and Exchange Act, in addition to providing the first industry Broker Dealer and Funding Portal Best Practices and Standards document.

Like many members of this Subcommittee, our organization was prepared for implementation of Title II of the JOBS Act on July 5, 2012 and for implementation of Title III of the JOBS Act on January 1, 2013.  And like many of you, we are concerned with the lack of guidance from the SEC surrounding both Titles.  We encourage your support in questioning the leadership, and specifically the Commissioners, regarding their prioritization of the JOBS Act regulatory process.

However, it is important to understand the hard work and dedication that has been shown by the staff in creating draft rules for the Commission.  The staff has been proactive in meeting with all members of the industry each time we have requested their presence, and has been extremely proactive in reaching out to us to discuss many aspects of the regulations surrounding the JOBS Act. In fact, we believe that the staff has had draft rules before the Commissioners since November 2012.

As you seek information from the SEC during your hearing on April 17, 2013, we encourage you to place your frustration and concern with the party most able to respond, and that party is the Commission, rather than the staff.  Like you, we all look forward to the Chairman and Commission calling the rules for Title III forward for public comment and finalizing the rules for Title II.




Candace Klein, Co-chair

Vincent Molinari, Co-chair

DJ Paul, Board Member

Freeman White, Board Member

Kim Wales, Board Member

Chris Tyrell, Board Member

Chris Camillo, Board Member

Scott Purcell, Board Member

Mike Dinan, Board Member

Joy Schoffler, Board Member

Ryan Feit, Board Member

Michael Norman, Board Member

Doug Ellenoff, Board Observer

Peter T. King, New York

Michele Bachmann, Minnesota

Sean P. Duffy, Wisconsin

Michael G. Grimm, New York

Stephen Lee Fincher, Tennessee

Randy Hultgren, Illinois

Dennis A. Ross, Florida

Ann Wagner, Missouri

Garland “Andy” Barr, Kentucky

Jeb Hensarling, Texas, ex officio

Spencer Bachus, Alabama,  Emeritus

The Crowdfund Intermediary Regulatory Advocates

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