The Securities and Exchange Commission’s Division of Trading and Markets assured two entities that, if they sought accredited investors for start-up companies they would not risk enforcement action by failing to register as broker-dealers under the Securities Exchange Act of 1934 Section 15(a)(1).  See FundersClub Inc. SEC No-Action Response, avail. 3/26/13.

In granting registration relief,

Like many others, my interest in the JOBS Act really started with crowdfunding.  This is probably because securities law is an imposing tangle of archaic acts, byzantine regulations and repetitive rules.  (Securities lawyers commonly say things like “…Rule 506 under Regulation D, promulgated pursuant to Section 4(2) of the ’33 Act…” and expect you to

George Washington famously (and perhaps apocryphally) compared the Senate to a cooling saucer, where the heated legislation from the more democratically accountable House could be considered by calmer, wiser statesmen.  Such thinking was the mark of sagacity in an era where the landed gentry feared political usurpation at the hands of rabble-rousing mobs.