Ontario Securities Commission
20 Queen Street West
19th Floor, Box 55
Toronto, Ontario M5H 3S8
RE: OSC Exempt Market Review - Comments on OSC Staff Consultation Paper 45-710
As the Founder and owner of Cdling Capital Services Inc. and the Founder & Director of the Toronto Chapter of Startup Grind, I am pleased to provide these comments on OSC Staff Consultation Paper 45-710. I am also the National VP of Startup Advocacy for CATAAlliance Invest CrowdFund Canada (ICC).
My primary issue for this letter is the advancement of investor protection measures that are designed for the current era of low cost, globally funded startups that we live in. This context is a direct result of new media forms, driven by new enabling technologies including ubiquitous broadband internet connections, low cost computing and powerful mobile computing devices.
My purpose is to pass on the advice that Marshall McLuhan might offer. At first any new media (or in this case the financing methods enabled by the new media), looks like something that came before it. An email looks like a letter. TV seems like radio before it, and so on. But eventually it becomes apparent that the new form is not the same as the old form. They have different dynamics and effects that demand different responses from us.
Crowdfunding is not a choice. To deny its adoption and significance is the equivalent of calling the internet a fad and adopting the position of an ostrich with your head in the sand.
Therefore, as you move to accept your responsibility to cope with this reality, please do not try to impose old frameworks for risk mitigation in this new context.
You can actually introduce more risk by doing so.