In a letter to Congress, Commissioners Piwowar and Peirce essentially dissented from the views expressed by the Securities and Exchange Commission (the SEC) regarding the offering threshold for Regulation A offerings. The SEC wrote to Congress noting that it did not at this time intend to raise the Tier 2 Regulation A threshold of $50 million. Commissioners Piwowar and Peirce expressed the view that there should be further consideration of the benefits to be gained by raising the offering threshold at the very least through a comment period. Their letter to Congress notes that the Treasury Report on capital markets included a recommendation to raise the Regulation A threshold to $75 million. The Commissioners’ letter also cites the passage by the House of the Regulation A+ Improvement Act that also included a provision raising the dollar threshold. The next opportunity for the SEC to consider the threshold would arise in the ordinary course in 2020.
