Our fifth crowdfunding live chat took place here on Crowdsourcing.org yesterday. The discussion continued to center around how the industry will take shape and the regulatory framework that will govern it. A very lively and informative discussion, as always. The full transcript follows, and you can find the transcript from the previous chat by clicking here.

Crowdsourcing.org Live Chat on Crowdfunding:
CfIRA Talks to the White House, SEC, FINRA, NFA

May 21, 2012

Transcript:
 

Jason Best : Hi, This is Jason Best from Startup Exemption

Kevin Berg Grell : Goodmorning everyone. Kevin Berg Kartaszewicz-Grell, CAPS Program Director at Crowdsourcing.org

sdav54 : Sharon Davison, Richardson & Patel

Jason Best : Hi, this is Jason Best, Co-Founder of Startup Exemption

EcoEinstein : Hi, Peter Einstein, Founder of Crowdfunding4Good -- a socially / environmentally responsible CF platform

Vincent Molinari : Greeting everyone

Kevin Berg Grell : Goodmorning everyone. Kevin Berg Kartaszewicz-Grell, CAPS Program Director at
Crowdsourcing.org

Kevin Berg Grell : Please announce yourself and your affiliation upon entering the LiveChat.

Lee Barken : Good morning!

Bill Joyce : Morning - Bill Joyce of North Texas CrowdFund Roundup

Chris Tyrrell : Chris Tyrrell, Right Strategies. Good day, all.

Kevin Berg Grell : If you have troubles logging in once the chat goes live, then please, try and refresh your browser, log in to Crowdsourcing.org and enter th

Charles Davidson : Hi, this is Charles Davidson, Vice President, Incorporating Services, Ltd.

Alejandro Cremades : Hello everyone, Alejandro Cremades, Founder & CEO of Rock The Post

Eyal Epstein : Hello from Israel to everyone

Vincent Molinari : Vince Molinari CEO Gate Technologies Co Chair of CFIRA

EcoEinstein : Peter Einstein, Founder - CrowdFunding4Good.com

Chris Tyrrell : Chris Tyrrell, Right Strategies. Good day, all.

Kevin Berg Grell : (cont.) 'and enter the chat.'

Eyal Epstein : Hello from Israel to everyone

Stephen Cohen : Hello group

Brenda Bazan : Hi, this is Brenda Bazan of Geode Partners

Stephen Cohen : Hello everyone

Vincent Molinari : Is DJ on?

Rhonda Love : Hi, this is Rhonda Love, CEO GF Crowdfunding

Amy Feldman : Hi there Amy Feldman at the Entrepreneurship Lab at Pace University

Scott Purcell : Hi, Scott Purcell at Arctic Island

Alejandro Cremades : Hello everyone, Alejandro Cremades, Founder & CEO of Rock The Post

Brad McGee : Brad McGee, Co-Founder, iCrowd

Amit Shah : Good Afternoon

Stephen Cohen : I am a regulatory attorney with Loeb & Loeb.

Darin Gordon : Darin Gordon, founder of Eudaimon - risk advisory and market data for the crowd

Svetlana Lebedev : Svetlana Lebedev, corporate/securities attorney at Ellenoff Grossman & Schole

Rhonda Love : Rhonda Love, CEO GF Crowdfunding

Amy Feldman : Hi there Amy Feldman at the ­Entrepren­eurship Lab at Pace University

Kevin Berg Grell : Today's panelists are Jason Best; Startup Exemption, DJ Paul; Crowdfunder.com, Vince Molinari; GATE Technologies

Kevin Berg Grell : Moderator is Candace Klein, SomoLend

Nick Jensen : I am a corporate and securities attorney with Lewis and Roca LLP

Eric Mack : Hi everyone, Eric Mack, Editor and News guy here at Crowdsourcing.org

Vincent Molinari : Jason do you want to start up an update on SEC Letter?

sdav54 : Sharon Davison, Richardson & Patel

Jason Best : Will do Vince

A. Brian Dengler : Hello.

Rhonda Love : Rhonda Love, CEO GF Crowdfunding

Vincent Molinari : Kevin I am not sure if Candace is able to join today

Lee Barken : Hi everybody... good morning!

A. Brian Dengler : Brian Dengler, CFIRA

Jason Best : CIFRA has sent comments to the SEC regarding general solicitation. Our goal in sending these at this time, is to help frame the debate

Jeff Bullock : Hi everyone, Jeff Bullock, Founder or LaunchpadInvestors.com

Jason Best : regarding general solictation prior to the July 5th date.

Jason Best : this will allow us to then further refine our comments WRT crowdfunding for the January 2013 deadline

Jason Best : we wanted to provide examples of the types of information that we suggested should be allowed in social media general solicitation

Kevin Williams : Hello everyone

Jason Best : Our comments should be available via the SEC Website within a few days

Darin Gordon : what is the tentative date for the next comment submission to the SEC?

Vincent Molinari : It is a great piece of work Jason. Can yoou direct all how they can view the letter if not seen yet?

DJ PAUL : DJ Paul here, Chief Strategy Officer for CrowdFunder.com. Sorry I'm late.

Vincent Molinari : I am not sure of the date, Jason anyone else on that?

Jason Best : I believe that the letter should be available on the CFIRA web site in the next day or two.

Vincent Molinari : Hey DJ

Brad McGee : I would suggest that any letter sent on behalf of the industry be thoroughly proof-read.

A. Brian Dengler : The letter is up.

Darin Gordon : hi DJ

Lee Barken : Have there been any further discussions about 'general solicitation' with regard to Title II (Reg. D exemption)vs. Title III (Crowdfunding)?

Brad McGee : The letter had 3 signers, yet had 5 errors, including typos and formatting issues.

Kevin Berg Grell : It's here:

Kevin Berg Grell : http://www.scribd.com/abdengler/d/94295409-General-Solicitation-Rules-Proposal-by-CFIRA-to-the-SEC

A. Brian Dengler : The letter is on the CFIRA site.

Vincent Molinari : great thanks Jason. If anyone needs ahead of time< ican email it let me know

DJ PAUL : Brad, can you send your corrections to us so we can update.

Vincent Molinari : That was fast, thanks Brian

Jason Best : Many thanks Brian

A. Brian Dengler : It would help if everyone would 'like' and share the CFIRA posting to get traction.

Vincent Molinari : Wow thanks Brad. Appreciate the heads up

DJ PAUL : So Vince, shall we move to questions or shall we discuss something specific. What do you want to update everyone about first?

Vincent Molinari : As a matter of quick update DJ Candace and I will be meeting w NFA tom to explore their possible role as SRO for portals

Vincent Molinari : absolutely DJ, just tossing out NFA topic

Darin Gordon : Vince: just to clarify-- the National Futures Association?

Stephen Cohen : I am curious, the NFA is a futures self regulatory organization, how would they be a likely candidate to move into regualtion in securities

Darin Gordon : Vince-- are you referring to the National Futures Association?

DJ PAUL : Is everyone clear on what the NFA is and why we are meeting with them?

DJ PAUL : Darin. yes.

Darin Gordon : @Stephen exactly

Vincent Molinari : Yes Darin

DJ PAUL : Stephen and Darin, the NFA has the ability to be the SRO for this space

Darin Gordon : what is the thought process supporting the decision to approach the NFA?

Stephen Cohen : Really that is most interesting

Vincent Molinari : Stephen the NFA appears willing to amend under 15A to seek an exemption to be the SRO for CF portals

DJ PAUL : It would require some hurdles to be jumped, but there is a mechanism by which the SEC could allow them to be the SRO rather than FINRA.

Stephen Cohen : Hmm, and what is FINRA's view on that?

DJ PAUL : You would have to ask FINRA.

Darin Gordon : has anyone conducted research on this-- what are the pro's of cons of going with the NFA vs FINRA?

DJ PAUL : We are in ongoing discussions with both Orgs, FINRA and NFA.

Vincent Molinari : We are engaged in conversations with Finra of course, keeping options open w NFA in order to achieve best outcome for CF equity

Stephen Cohen : That would seem top open pandora's box to enable NFA to regulate other securities and brokerage related transactions in future. Not somethin

Robert Banek : Robet Banek, Funds4Geeks

DJ PAUL : Stephen, why a 'pandora's box'? What is your concern?

Stephen Cohen : I totally agree with your approach. Sorry, I work in the industry for 20 years so I am very close to these organizations.

Vincent Molinari : stephen in order to that they would have to become full 15A registered which is unlikely

Lee Barken : Even if they wanted to pursue this, what is the timeframe in which NFA could become an SRO?

Vincent Molinari : the objective is to explore all possible outcomes to achieve the best result, although most assume its a given to have Finra as SRO

DJ PAUL : NFA is an SRO already, but it is correct to assume that is the NFA were to be the SRO for Crowdfuning, it would take at least several more m

Stephen Cohen : Yes most unlikely. FINRA hwoever seems the more natural fit and one that I would think Congress would be more inclined to favor, not that th

DJ PAUL : months

EcoEinstein : Whatever we do, we can't have FINRA & NFA end up in a turf war over this-- holding everything up.

Eyal Epstein : Can a foreign owned platform do CF in the US?

Vincent Molinari : Lee that is the main hurdle, it is a loss of time. NFA exec board would have to approve in july meeting, full BOD approval in Aug

Stephen Cohen : To answer the person who asked pros and cons, there are definitely both for each SRO

Darin Gordon : one bottlenecking regulator is enough

DJ PAUL : Eyal, that is unclear. The portal would certainly have to register with SEC and comply with all laws and regulations of both the SEC and

DJ PAUL : whichever SRO governs

Lee Barken : Sounds encouraging to have a little competition in the space.

Vincent Molinari : agree Eco, however I am not sure either consider this so valued to engage in a battle over it

DJ PAUL : Lee, exactly.

Jason Best : I think the issue for me is will FINRA fully and fairly represent crowdfunding given their stance on the issue prior to passage

Kevin Berg Grell : Are there specific pros and cons for going with NFA rather than FINRA?

Eyal Epstein : Thanks DJ, this is what i thought I understood also

Eyal Epstein : Thanks DJ

DJ PAUL : Pros and Cons: FINRA is faster. Requires no additional dispensation from SEC.

Stephen Cohen : I beleive that NFA is a softer touch SRO.

Lee Barken : Jason: correct... maybe they will be willing to let go of that 'turf' if they think it's 'toxic' territory... (?)

DJ PAUL : Cons to FNRA: they may not be as friendly to the space ultimately.

Darin Gordon : Does is make sense to work together and summarize pros/cons of both and then use that for the CfIRA leadership to then decide who to work w/

Jason Best : great idea Darin

EcoEinstein : Good idea, Darin

Stephen Cohen : NFA registration for example is much swifter and less intense on an ongoing basis. FINRA would have to create a whole new set of rules diffe

Vincent Molinari : I think that is correct stephen although I have to say that finra has been very open and engaged. they appear to have a better understandi

Nick Jensen : Is it a foregone conclusion then that either FINRA or NFA will govern as the SRO and that a new independent SRO will not be created?

Darin Gordon : I can help facilitate this work but have no input to give on either at the moment

Tim Witt : if you are in favor of finra you have probably never been regulated or audited by them

Vincent Molinari : all for it darin

Darin Gordon : ok who wants to be included

Stephen Cohen : I have not been involved with this until today, however very happy to particpate and assist in dialogues. Who are yous peaking with at FINRA

DJ PAUL : Darin, I think you will be able to glean enough info after this chat to start such a list.

Kevin Berg Grell : Darin, I'll give you all the contact details you need after the chat :-)

Vincent Molinari : Finra sent several staff members to the last TSL event Thurs to listen to presentations. There will be additional direct follow up with the

Darin Gordon : @Kevin thx

Nick Jensen : Hi all, this is Nick Jensen, a corporate and securities attorney with Lewis and Roca LLP.

Kevin Berg Grell : @Stephen; Please reach out to candace@somolend.com after the chat.

Chris Tyrrell : I agree with the parallel-track strategy. FINRA gets us speed and a model-in-development; NFA gives us an alternative.

Nick Jensen : Is it a foregone conclusion then that either FINRA or NFA will be the SRO and that a new independent SRO will not be created?

Vincent Molinari : thanks stephen. we have been dealing with various folks in both dc and nyc offices. happy to send a list later

DJ PAUL : Nick, to set up a new SRO would be incredibly time consuming and costly. Could take years.

Stephen Cohen : Will do. Look forward Vince. I can tell you who I know on it.

Chris Tyrrell : I agree with the parallel-track strategy. FINRA gets us 'speed' and a starting point; NFA gives us an alternative / comparison.

Vincent Molinari : Nick yes at this juncture. the sheer cost of establishment and ongoing operation to become an SRO is too prohibitive

Darin Gordon : doesnt history show us that where there's a will there's a way? (JOBS Act)

Vincent Molinari : exactly chris, well put

DJ PAUL : Further to a setting up a new SRO: it might be able to be done, later, in a couple years, when the space is more mature.

Kevin Berg Grell : Great SRO discussion, but maybe we should move on to some of the other issues that have come up..

Kevin Berg Grell : Any thoughts on what a safe harbor should look like from the investment advice triggers

Vincent Molinari : sure kevin

Stephen Cohen : I absolutely agree that at some point you would want to invest in creating a SRO made up on portal members only wuith portal member interest

Stephen Cohen : However that looks a few years out once this industry matures a little. And with repsect to Kevin I will stop talking about SROs now

DJ PAUL : Kevin, thanks for keeping us moving. So, SAFE HARBORS. Is everyone clear what we mean by that?

Vincent Molinari : love it stephen thanks happy to continue post chat too

Darin Gordon : @DJ: could you please clarify

Kevin Berg Grell : @Stephen; Let's continue the SRO debate in the LinkedIn Group

Kevin Berg Grell : http://www.linkedin.com/groups?gid=4415199&trk=hb_side_g

Chris Tyrrell : A safe harbor is a defined set of behaviors/actions that the SEC will agree in writing will keep platforms in compliance / out of liability.

DJ PAUL : Thanks, Chris.

Darin Gordon : so for example, posting the vetting process in terms & conditions so to avoid the 'investment advice' issue?

EcoEinstein : Also, a nice place to keep your boat

DJ PAUL : Safe Harbors define a lack of liability for specific behavior in which good faith of the actor is presumed.

Stephen Cohen : Haha Eco, What is the investment advicew issue, is it a concern about being required to register as an invetsment adviser?

John Romano : John with Virtual Capital Group, does anybody have any observations on what a Portal can or cannot do in addition to the match making?

Nick Jensen : Stephen, I believe the investment advice issue is the JOBS Act prohibition against funding portals giving invesment advice

EcoEinstein : And can we make recommendations about non-investment issues, eg: whether a company is eco-friendly

Vincent Molinari : it has become on hot issue as to what the SEC may deem portals giving investment advice as they are prohibited from doing so in the legislat

Chris Tyrrell : @Darin - yes, one 'safe harbor' with respect to 'not providing investment advice' that we are expecting is that vetting terms and (cont'd)

Chris Tyrrell : conditions will permit us to keep prospective companies off of our platforms without that being construed as 'investment advice'

Darin Gordon : @Eco: that influences investment decisions (advice)

Jason Best : the comments we've heard fromt he SEC indicate that if your T&C's list types of companies that you dont want on your platform...

Brad McGee : But what about potential triggers to investment advice based on how a listing is presented?

Jason Best : then this is not advice, but your standard practice

Brad McGee : For example, what if you post how many Facebook friends are investors in a listing (cont)

Brad McGee : is that advice (since you are implying it's a good thing)?

EcoEinstein : Would it make sense for CfPA to creative some standarized language in that regard?

Vincent Molinari : my apologies as i have to join another call. DJ and Jason i believe you can stay the balance?

Darin Gordon : I'm sorry to backtrack a bit but I raised an earlier question about schedule for posting comments to the SEC. when is next?

DJ PAUL : Eco, in regard to what? What kind of language? Can you give me an example?

DJ PAUL : Vince, I will be here, yes.

Brad McGee : What about other practices that might trigger investment advice? For example, (cont)

Vincent Molinari : in case my email is: vmolinari@gatetechnologies.com thanks everyone, my apologies again

Jason Best : @vince, I'm here also

Darin Gordon : @vince thx

EcoEinstein : Regarding a site's acceptable guidelines. What it can use to accept or deny a company

Brad McGee : if you indicate how much of a listing's investment is from Facebook friends, is that (cont)

Kevin Berg Grell : Talk later Vince.

Brad McGee : investment advice - since you are implying more friends investing is good?

Lee Barken : In other words-- can funding portals have 'ratings' posted within a safe harbor that are not considered 'investment advice'

Erick Alexander : Thanks Vince.

DJ PAUL : Brad, its an interesting question. And while I cannot be definitive, I would think that would not be considered advice.

Darin Gordon : @brad I think that's more of an assumption.. the only fact you present is social network data

Chris Tyrrell : DJ and Jason, perhaps it would be best to draft an initial list of safe harbors, and then offer them to the group for comments, offline?

Jason Best : I think we need to send comments to the SEC regarding how ratings work, and how they are not investment advice

DJ PAUL : Lee, Ratings would probably be a no-no.

Svetlana Lebedev : Lee, a ratings system probably crosses the line in terms of giving advice

Nick Jensen : I agree that ratings are probably a no-no

Brad McGee : But in the case of @Lee's comment, what if the ratings are from other investors and not the site?

Jason Best : @Chris, yes, that would be great

DJ PAUL : Jason, yes, I think we need to make that argument. Because the sense I have is that ratings are advice, ipso facto, accordnig to SEC

Lee Barken : If a person's credit score was published, is that a 'rating'?

Darin Gordon : I assume that a portal can however share ratings from a 3rd party advisory

Brad McGee : And what about comments that other potential investors make concerning a potential investment?

Jason Best : What about showing where your investors are coming from in your social network? just reporting that data e.g. 30% from 1st degree connects,

Jason Best : 50% from 2nd degree, etc

DJ PAUL : Darin, I would not assume that. Outsourcing ratings to a 3rd party is not a fgood work around. The SEC would likely see thru that.

Darin Gordon : @DJ: is it possible for the 3rd party to list the portal's listings and provide the advice in that way?

DJ PAUL : Jason, not sure. But that sounds ok.

Alejandro Cremades : @Brad, that is a good question. If there are ratings on the site the portal might be consider also as a promoter

Kevin Berg Grell : So what is the plan, is CfIRA going to provide an example of what a safe habor could look like for crowdfunding?

Nick Jensen : A person's credit score is a 'rating' but credit rating agencies are exempt from the investment advisers act of 1940

Alejandro Cremades : I agree with DJ. Might be a good idea to stay away from them

Darin Gordon : there is no language on what an advisor can/can't do

DJ PAUL : 3rd party can do what its wants. The question is what the portals can do and list.

Erick Alexander : I think ratings can be a two-hedged sword. Potential manipulation?

EcoEinstein : What if the platform clearly states that these are the terms under which a company will appear on our platform...

DJ PAUL : Darin, there actually IS quite a bit of language regarding investment advice and what constitutes it.

DJ PAUL : But in short, the SEC will define advice VERY broadly.

Jason Best : I think CfIRA should come up with a draft list of safe harbor provisions and examples of how social media works within that context

Brad McGee : @Darin - it is spelled out in the Investment Advisors Act, but there is a lot of interpretation and case law.

Darin Gordon : sorry I wasn't clear-- I meant terms covering the 3rd party (not portal)

Lee Barken : I wonder if that's why the McHenry Bill's requirement for a comments page was removed...?

DJ PAUL : Jason, totally agreed.

Darin Gordon : in re crowdfunding?

Alejandro Cremades : @Jason, I think that is a good idea. We need to make sure this point is clear

Lee Barken : Is the crowd communicating with each other considered investment advice, etc...? Seems like that's more '3rd party'

Kevin Berg Grell : @Jason; great idea... Do we have a timeline for this effort?

A. Brian Dengler : I agree with Jason's idea on coming up with a list.

Chris Tyrrell : @DJ and @Jason, I would be happy to spearhead the draft, and commit to a two-week deadline.

Svetlana Lebedev : @ Jason, what if a portal shows investors the percentage of voluntary information made available by an issuer.

Chris Tyrrell : @DJ and @Jason, I would be happy to spearhead the draft list and commit to a two-week deadline.

DJ PAUL : Chris, take it away. Sounds good.

EcoEinstein : Jason's idea is especially important in the areas that are not directly linked to ROI, such as social responsibility.

Svetlana Lebedev : This is not advice but it will distinguish issuers

Chris Tyrrell : Kevin, perhaps another shift of topic, and people can send me their 'safe harbor' ideas? I'm chris@rightstrategies.com.

DJ PAUL : Eco, that kind of carve-out/safe-harbor might be possible. And valuable, yes.

Jason Best : @ Chris, thank you! 2 weeks is a great timeline

Kevin Berg Grell : @CT; Alright; I think I'll leave it to Jason and DJ to pick the last topic for this chat.

DJ PAUL : And I leave it to Jason, as he is smarter than I am.

EcoEinstein : Don't underestimate yourself, DJ...Not everyone is an Einstein :-)

Sherwood (Woodie) Neiss : @DJ .... i can see this

Jason Best : Is there any other comment area that this group thinks we should be addressing ahead of the July 5th date for general solicitation?

Jason Best : meaning, are there topics that we should be addressing now, that will help frame later discussions with the SEC?

Jason Best : safe harbors is one...

Jason Best : how social media works is another

Darin Gordon : @Jason yes-- information on clearing services

Kevin Berg Grell : I think it would be helpful to know what can be announced outside the funding portal.

Nick Jensen : What will be the safe harbors for using appropriate efforts to ensure that investors do not exceed their annual investment threshold?

EcoEinstein : What about the ability of platforms to work cooperatively, referring / sharing leads?

Charles Davidson : I would be very interested in requirements for entity formation on the start-up side. and vetting on the investor side

Kevin Berg Grell : I.e. Can I solicit my CF project on LinkedIn, FB or similar...

Charles Davidson : I would be very interested in ­requireme­nts for entity formation on the start-up side. and vetting on the investor side

Nick Jensen : Do we know what the rules will look like regarding investment in crowdfunding by entities (e.g. corporations, LLCs, partnerships)?

Jason Best : @kevin, we have some of that covered (I think) in the comments we just submitted to the SEC, but could add more if we need to

Svetlana Lebedev : Don't know if this was discussed already but whether a portal can permit investors to announce their investments on social media websites?

EcoEinstein : @Svetlana -- Would that be a prohibition of free speech?

Bob Thibodeau : Has there been any discussion about non-affiliated liability (publishing others comments), or associative liability for same?

DJ PAUL : ECO, the SEC prohibits lots of speech. Note the 'quiet period' for traditional IPO's, for example.

Jason Best : @Svetlana, we provided some example posts (of various lengths) of what we would propose to allow posting on social media sites

Nick Jensen : @Eco - no, that would be commercial speech, more easily regulated; they can't prohibit you from saying it, but they can deny the CF exempt

Charles Davidson : @Svetlana I would think that Investors sharing there own personal decisions publicly could not be prohibited, practically speaking

Svetlana Lebedev : @Eco, It may implicate general solicitation rules.

EcoEinstein : But Svetlana was referring to individual investors

Darin Gordon : I would like to help draft a section regarding standards for data interoperability among crowdfunding service providers

Nick Jensen : The JOBS Act does not place any such restriction on investors

Charles Davidson : as this grows and general fincanial IQ falls, it is going to happen regardless of the rules

Svetlana Lebedev : @ Eco, we know this is the practice by the UK portals

DJ PAUL : While it is still not decided, I think that investors will be able to tell their friends what they invested in and why.

Svetlana Lebedev : @ Nick, the SEC may restrict this practice by portals

EcoEinstein : @Svetlana -- What is? Allowing or NOT allowing mention of personal investments?

Bob Thibodeau : I've tried to ask 2 questions, are they delayed?

Darin Gordon : Bob: click 'make public'

Nick Jensen : @Svetlana, meaning that portals could not host a comment board or similar where investors say what they invested in?

DJ PAUL : Bob, I have not seen your questions.

Kevin Berg Grell : @Bob; please re-post as public.

Bob Thibodeau : the first is, is there any sense of associative liability, that is for a website to publish someone elses comments, and secondly, is there a

A. Brian Dengler : There are sites up already where users discuss investments, e.g., bloggingstock.com. These sites prohibit stock touting and solicitation.

Charles Davidson : @Nick could the portal post a list of the investors for a particular project?

Lee Barken : Would a 'portal' engaging in general solicitation of securities be required to register as a broker/dealer?

Chris Tyrrell : @Darin - a CfIRA working group is forming on data issues

Bob Thibodeau : an associative liability for comments made offsite?

Darin Gordon : Jason, DJ, and all -- thank you very much for today's chat

Jason Best : Thanks to everyone for your comments

Bob Thibodeau : @charles, it would seem that the publication of investor names for a particular project would violate existing banking laws and finra regula

Darin Gordon : thank you Chris, I look forward to discussing

Kevin Berg Grell : Guys we are running out of time.

A. Brian Dengler : Can I bring up one item?

A. Brian Dengler : Can someone send me the letter that went to the White House for use on our CFIRA site?

Kevin Berg Grell : Will do..

EcoEinstein : Thanks everyone! @DJ: Nice meeting you in NYC! :-)

A. Brian Dengler : Thanks!

DJ PAUL : You too. Thanks to all.

Nick Jensen : @Charles if the investors permitted such use I don't think it would violate the CROWDFUND Act

Kevin Berg Grell : Everyone, thank you for a great debate. We will have the Summary up on the Editorial section in a few days.

Rhonda Love : Thanks everyone...have a great week.

Kevin Berg Grell : Please direct any inquiries to Co-Chair Candace Klein: candace@somolend.com

Charles Davidson : thanks

Lee Barken : thanks all

Alejandro Cremades : @Jason, @DJ, @Vince, and @Kevin. Thanks so much for the chat! alejandro@rockthepost.com

Kevin Berg Grell : And have a great week -- and remember to check CfIRA's LinkedIn group for further debate.

Charles Davidson : very interesting Charles Davidson cdavidson@incserv.com Incorporating Services Ltd. www.incserv.com

DJ PAUL : dj@crowdfunder.com