5/21/2018 Comparative Analysis of Crowdfinance
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COMPARATIVE ANALYSIS OF CROWDFINANCE
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TITLE II: Private Issuers TITLE III Crowdfunding (proposed)
Publicly Raising (PIPR)
Reg D 506c exemption 4(a)(6) exemption
FORM D filing FORM C, C-U, and C-AR filings
No audited financials and no annual Audited financials and
annual reporting for
reporting requirement offerings in excess of $500,000
Costs vary depending on Costs vary depending on banking fees if
anybanking fees, if any
No offering limit $1M offering limit every 12 months
Must provide SEC verification that issuer Limited general
solicitation, such as
or intermediary confirmed that purchasers tombstone ads
directing investors to portal
were accredited
Intermediary or funding portal not required Must use funding
portal or registered
intermediary
ADVANTAGES ADVANTAGES
Can raise unlimited amount without Title III Unlimited number of
shareholders
disclosure burden; unlimited advertising Can help convert
customers into
opportunities shareholders
DISADVANTAGES DISADVANTAGES
New burden on issuer or intermediary to $1M cap on annual raise;
more reporting
confirm with the SEC that accredited investor requirements than
with Title II; disclosure
status was verified demands may be costly; all 4(a)(6)
investors
must fully comply
