Historical document — 2019 SEC comment letter. This page was rebuilt on October 3, 2026 to restore access to the original letter. The original blog introduction has not been recovered.
Joe Wallin, James Graves, Zach Haveman, Danny Neuman, and Bryant Smick submitted comments on the SEC’s Concept Release on Harmonization of Securities Offering Exemptions (File No. S7-08-19). The SEC records the letter as received on September 23, 2019.
Read the original signed SEC comment letter (PDF)
The letter discusses access to capital for startups, participation by non-accredited investors, the accredited investor definition, Form D, crowdfunding, and proposed micro-offering exemptions. It presents the authors’ recommendations in 2019; it is not a statement of current securities law.
