Reg A+ Challenged Again

Another letter to the SEC from the Hill challenges the Regulation A+ proposal. This time, the authors question the authority of the SEC in defining "qualified purchaser" as an offeree or purchaser in a Tier 2 Reg A+ offering. The letter (available here: http://www.nasaa.org/wp-content/uploads/2014/08/Senate_Regulation-A-Letter-FINAL-08-01-14.pdf) suggests that the SEC through the approach taken in its proposal ignores investor protection concerns. This seems odd. Investor protection always has been premised on a disclosure regime. The SEC's Reg A+ proposal sets quite a high bar for Tier 2 Reg A+ offerings, such as incorporating in the proposal:

• substantially enhanced requirements for information to be set forth in an offering statement to be reviewed and qualified by the SEC;