Filed on the exact same day that the request for comments were open on the Securities and Exchange Commission platform, the state of Massachusetts posted a comment letter regarding proposed regulations for the new Regulation A under Title IV of the JOBS Act of 2012.
In a blistering missive, William F. Galvin, Secretary of the Commonwealth for Massachusetts, lambasted the federal regulators. Â Galvin, the chief securities regulator for the state of Massachusetts, stated he was “dismayed” and “shocked” regarding the proposal to pre-empt the ability of states to require registration and review them. Â The written communication filed on December 18, 2013 was followed up with a scheduled phone call involving representatives of Commissioner Kara Stein’s office and representatives of Galvin’s office on January 10, 2014.
Regulation A or “Reg A” in it’s current form has been a lightly used method to offer securities largely do to the  cumbersome requirements surrounding the regulation.  Title IV of the JOBS Act was an attempt to rectify this situation. Alternatively over $900 billion in capital was raised under Regulation D offerings in 2012.
Secretary Galvin, who has been Secretary since 1995, has been a vocal opponent of the JOBS Act and crowdfunding. Â He believes, “…that the law was essentially opening the door for those with a history of defrauding investors”.
Comments are being accepted for 60 days after publication in the Federal Register.
The comment letter is posted below.
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