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> Private shared ownership could’ve been membership interest in an LLC managed by Carta or similar. LLCs have no membership limit unless taxed as an S corp (to

> Private shared ownership could’ve been membership interest in an LLC managed by Carta or similar. LLCs have no membership limit unless taxed as an S corp (to my knowledge). You can’t offer membership interest to the public unless you are registered with the SEC and in compliance with the states you make your public offering. There are some exceptions to the SEC for limits much lower than the ~$30M raised as of now.

toomuchtodo 5y ago
Nor can you with crypto. I suggested the path avoiding unnecessary tech, the regulatory requirements apply regardless. An SEC complaint would likely clear the matter up, if anyone is feeling particularly adventurous.
- shiftpgdn 5y ago
  I believe they only have to fulfill the SEC requirements if there is an expected return on investment.
  - deleted 5y ago
    [deleted]
- throwawaycities 5y ago
  but they didn’t offer a security or investment contract, they offered a token that gives holders a form of governance/voting. You are saying you offered a suggested oath to “avoid unnecessary tech”, but you removed the concept of a voting right for a security. There is plenty of precedent of the SEC responding favorably to “no action letter requests” without requiring registration when organizations publicly offer voting/governance rights in exchange for money.
- throwawaycities 5y ago
  but they didn’t offer a security or investment contract, they offered a token that gives holders a form of governance/voting. You are saying you offered a suggested path to “avoid unnecessary tech”, but you removed the concept of a voting right for a security by suggesting they could have offered interest in an LLC. There is plenty of precedent of the SEC responding favorably to “no action letter requests” without requiring registration when organizations publicly offer voting/governance rights in exchange for money.

toomuchtodo 5y ago

Nor can you with crypto. I suggested the path avoiding unnecessary tech, the regulatory requirements apply regardless. An SEC complaint would likely clear the matter up, if anyone is feeling particularly adventurous.

shiftpgdn 5y ago
I believe they only have to fulfill the SEC requirements if there is an expected return on investment.
- deleted 5y ago
  [deleted]
throwawaycities 5y ago
but they didn’t offer a security or investment contract, they offered a token that gives holders a form of governance/voting. You are saying you offered a suggested oath to “avoid unnecessary tech”, but you removed the concept of a voting right for a security. There is plenty of precedent of the SEC responding favorably to “no action letter requests” without requiring registration when organizations publicly offer voting/governance rights in exchange for money.
throwawaycities 5y ago
but they didn’t offer a security or investment contract, they offered a token that gives holders a form of governance/voting. You are saying you offered a suggested path to “avoid unnecessary tech”, but you removed the concept of a voting right for a security by suggesting they could have offered interest in an LLC. There is plenty of precedent of the SEC responding favorably to “no action letter requests” without requiring registration when organizations publicly offer voting/governance rights in exchange for money.