(Disclosure: I am on the ACA’s Public Policy Advisory Council)
The folks at the ACA have been critical in helping positively influence public policy on angel investing in the last several years.
Just to give you one example that you may or may not recall, but the first iteration of Dodd-Frank would have re-set the “accredited investor” financial thresholds for inflation going all the way back to the 80’s. That proposal, if it had been enacted, would have wiped out literally 3/4ths of all angel investors. The second iteration of Dodd-Frank was worse—it would have required all Rule 506 offerings to first be submitted to the SEC for 120 days for review, and if the SEC didn’t review then states would have been given the chance to review before offerings could go forward.
But for the involvement of the ACA, and folks like Dan Rosen and Senator Maria Cantwell, these things could have happened. Being involved is important. The upcoming ACA summit will be a great way to get started, if you are looking for a way.
Now is a critical time for angel investing in America. The SEC is currently evaluating a number of different issues that will have a dramatic impact on angel investing, such as:
- The definition of “accredited investor.” It is possible that the SEC will propose to modify this definition to “define out of the game” a huge swath of the population that currently qualifies as accredited. See the ACA’s letter to the SEC.
- The proposed Regulation D and Form D rules, that will require advance filings of Forms D and onerous consequences to companies if they file to advance file before they “generally solicit” their offerings.
(If you want to see the former Chair of the ACA, Catherine Mott in action, read the transcript of this SEC open meeting in which she questioned the SEC on whether demo days constituted “general solicitation.”)
Policy makers need the input of people who are active in the early stage company ecosystem.
“We are hosting this meeting in Washington, D.C. for a reason,” ACA’s Chair David Verill said. “The Securities and Exchange Commission is not only assessing the underlying definition of who can be an accredited investor, but is also reviewing significant rules around the JOBS Act involving general solicitation and online crowdfunding platforms. Now more than ever is the time to join with angel colleagues to learn about, to shape, and to nurture this powerful economic engine.”
2014 ACA Summit
Angel Impact: Entrepreneurial and Economic Success
March 26th – 28th
If you plan to attend, please let me know and I can try to connect you to friends who will be there.