Observations Drawn From SEC’s Crowdfunding Proposal

Even if you have no interest in crowdfunding, there are a number of interesting elements in the SEC's crowdfunding proposal that may have broader applicability.

Phased disclosure:  the crowdfunding proposal incorporates a number of information requirements.  An issuer that intends to engage in a crowdfunded offering must prepare certain disclosures, which will be filed on Form C.  The Form C would include basic information about the company and its business, information about its officers, directors and principal shareholders, its use of proceeds, a description of capital stock, related party transactions, recent securities offerings, a description of financial results (similar to an MD&A), etc.  These disclosure requirements acknowledge that a one-size-fits-all disclosure model may not be appropriate.  The SEC seems to have given thought to those disclosures that would be most relevant for an investor, and has tailored the disclosure requirements.  Might this signal