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On April 5, 2012, President Obama signed into law the Jumpstart Our Business Startup Act, or “JOBS Act,” which exempted certain “crowdfunding” activities from the registration requirements of the Securities Act. The Securities and Exchange Commission (SEC) was supposed to promulgate rules by Jan. 5, which—subject to statutory boundaries—would implement the crowdfunding exemption. It failed to do so. Six months later, the SEC has not even issued initial proposed regulations. In the meantime, public comments to the SEC on the need and specifics of crowdfunding continue to roll in, and the small business community stamps its foot impatiently.