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I know you're serious.

But consider that the SEC has been responsive to input on this very subject after previous consultation - and I really don't think a policy review is inappropriate, in the wake of a financial meltdown. And while 412 does indeed have 2 parts, it's clearly a placeholder directive, pending a year long review of both accreditation and regulation of private capital by the Comptroller's office mandated in 413.

Now here's how I look at it: Goldman and other large institutions are politically radioactive right now. We could debate whether or not that's fair, but there it is. Public support for Wall Street is at a low ebb, and Congressional Republicans have decided to debate financial reform rather than fight the tide. The big issues are bank liquidation, derivatives markets, and who will regulate consumer finance - neither the GOP nor the White House are too hot on creating a new agency that might get into fights with existing ones. this investor accreditation issue is way down the list. You should certainly call your senator to express opposition if that's how you feel, but: a) for the many tech startups & VCs in California, that's Dianne Feinstein who is unlikely to empathize; and b) it's easier for Congress to delegate the nitty-gritty details to the agencies. Frankly, I'm surprised the bill isn't more prescriptive on this issue.

So suppose it passes. Two new factors come into play. One is that the SEC will hold their public consultation as discussed, and we can predict a negative reaction from startups, angels and VCs. Given the parallel review and the weak recovery so far, it's possible - I think likely - that the SEC will prefer not to introduce job-killing rule changes that would block access to capital in the short term, but wait on the other agency.

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EDIT: I mixed myself up royally earlier, talking about the 'Comptroller of the Currency' when what I should have written was 'Comptroller General' - part of the GAO. I then looked back to my own text for further reference, perpetuating the mistake through two more paragraphs to no meaningful purpose. Sorry.

I do still think that the year-long review of accreditation and fund regulation is important to HN readers.

New factor two is that in August, John C Dugan will finish his term as head of the OCC (main commercial bank regulator

[... EPIC ACCURACY FAIL....]

small business is something that's easy to sell for both Democrats and Republicans.

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So again, I respect your skepticism about the bill as a whole; but passage of it could increase opportunity rather than just cost.




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