CfPA's Reg CF ask quadruples a cap that the last increase multiplied by nearly five

In multiple terms the proposed increase is the smaller of the two moves: $1.07 million to $5 million was about 4.7 times, and $5 million to $20 million is 4 ^[2]. Belley's evidence for the second is what he says the first produced. "At Kingscrowd, we clearly saw a jump in the types of issuers that entered the market when the cap was raised from $1.07M to $5M, bringing in more mature issuers for whom that made a difference," he said ^[7]. He also said, "Retail investors shouldn't only get access to companies that couldn't raise elsewhere" ^[8].

The two numbers he wants keep the ladder steep. At $150 million, Reg A Tier 2 would sit at 7.5 times the $20 million he proposes for Reg CF ^[4]. His stated principle, per Crowdfund Insider, is to scale the exemptions to the issuer's size and maturity, cut regulatory friction that does not provide meaningful investor protection, and pay more attention to what happens after the raise ^[15].

The accredited-investor test operates elsewhere. Reg CF and Reg A offerings are open to retail participation; Reg D 506(c) is the exemption restricted to accredited investors ^[1]. So the $200,000 income bar, $300,000 for a married couple, or $1 million of net worth excluding a primary residence, decides which exemption an issuer's investor base can come through ^[2]. Those are nominal dollars from the 1980s ^[3]. The couple test behaves oddly at the margin: two earners at $140,000 each report $280,000 of household income and fail, while a single filer at $210,000 clears the individual bar ^[3].

Crowdfund Insider, which put the questions to Belley, wrote that the rule "still acts as a barrier for most of the population, as it discriminates against individuals who are less affluent but may be very sophisticated in capital markets" ^[3]. The fixes collected in the same piece are the caps, financial statements scaled to offering size and operating history ^[10], advertising and communications rules that Belley says create inadvertent compliance traps most issuers do not understand ^[11], and annual reporting the SEC should make dramatically easier with automated reminders and a simpler filing interface ^[12].

The SEC's proposed Regulation Crypto Assets would allow a startup exemption of up to $5 million on principles-based disclosures, with financial statement and ongoing reporting requirements attaching to larger offerings under its fundraising exemption ^[13]. That ceiling is the same $5 million a Reg CF issuer works with today ^[5], on a different disclosure schedule, and the article argues against a patchwork of exemptions carrying materially different burdens absent a meaningful reason for the difference ^[14].

On the evidence here, the cap governs the composition of the issuer pool. The number that would settle whether it also governs the pool's size is the share of raises at or near $5 million, and the source does not supply it. Belley reports the pushback himself: so few raises hit the cap today, why raise it, to which his answer is a lower cost of capital for entrepreneurs and access to higher-quality deals for investors ^[9]. If the distribution turns out to be clustered far below the ceiling, the filing interface is worth more per unit of effort than the cap. Crowdfund Insider frames the whole list as reachable through rule changes or legislative action, without saying which path each item needs ^[16].