Well, as we’ve already pointed out, it will not be legally or logistically possible for the SEC to have its crowdfunding regulations in place by December 31. Some commentators have speculated that we might get the proposals December. Or January. All I can say with respect to timing is that at a tribute dinner on Thursday night I was sitting next to an old SEC friend who had recently had cause to go through some memos that I had written when I was a young SEC staffer, confidently predicting that we would have draft proposals to present to the Commission within a matter of weeks. Those proposals were eventually presented to the Commission two years later.
I don’t want to scare anyone and we’re not looking at anything like two years here, I’m sure. But after spending some time with the Staff at the SEC’s Small Business Forum and the ABA Business Law Fall Meeting last week, I think we need to get a few things into perspective. Sitting here in our crowdfunding bubble, we focus on the fact that we need those regs to get out and recreate the capital markets, and crowdfunding regulations are the most important thing in the world for us all right now. But they aren’t the most important thing for the SEC, and you know what? They shouldn’t be.
