While there are no doubt benefits to allowing at least indirect retail participation in private issuers, there should not be any neglect of the tasks of re-examining the regulations imposed on public companies. One reason why more issuers stay private is that going public costs more than the benefits it provides.  

Since its adoption, Form PF has been an exemplar of ill-considered information-gathering requirements by the government. (See, e.g.,  (July 31, 2013)).

Before adding the new requirements, the regulators should provide a clear explanation of just what value it is that they derive from the Form. It should have been obvious from the time of the Form's adoption, that pretty much all of the questions were so poorly drafted that there could be no other result than GIGO. …

Can it really be the case that a Governor of the Federal Reserve cannot be removed from that position following the discovery that she may have committed an economic fraud before assuming office? Even if it turns out that the fraud continued and was not corrected after the Governor assumed office? This logic is made even more disquieting given the brief recitation by the Court as to the conduct of Governor Cook with regard to alleged mortgage fraud. The facts as described, do not look good…

The rules at issue were not well-drafted as to the details and were overly expansive in the big picture. Salvaging the rules would seem to require a do-over. It is hard to imagine why that should be a good use of SEC resources.