Hester M. Peirce is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent public statement. The views expressed in this post are those of Ms. Peirce and do not necessarily reflect those of the Securities and Exchange Commission or its staff.
Today’s [March 4, 2020] proposed rules are a welcome next step in the Commission’s efforts to simplify, harmonize, and improve our exempt offering framework. This proposal, which follows last year’s harmonization concept release and proposed amendments to the accredited investor definition, reflects a healthy regulatory habit—reviewing rules in light of their implementation and our experience to see what is working, what is not, and where there are gaps. I commend the staff in the Divisions of Corporation Finance, Economic and Risk Analysis, and Investment Management, and others throughout the building for their hard work on this release. Chairman Clayton has made it a priority to remove unnecessary friction from the capital-raising process and this proposal is the latest fruit of that important initiative.
I am grateful for the comments we received in response to our concept release and look forward to further comment in response to this proposal. I hope to hear from commenters not only about the proposed reforms, but also about possible additional reforms. Some of the questions I have been asking include the following: