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October 9, 2007 VIA E-Mail Ms. Nancy M. Morris Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 rule-comments@sec.gov Re: Release Nos. 33-8828; IC-27922, (File No. S7-18-07) Revisions of Limited Offering Exemptions in Regulation D. Background The National Venture Capital Association (NVCA) represents the vast majority of 1American venture capital under management. Venture capital funds provide start-up and development funding for innovative entrepreneurial businesses. Venture capital plays a special role in fulfilling the purpose for which Regulation D was designed: facilitating capital formation. Indeed venture capital supports the ultimate goal of capital formation by promoting entrepreneurship, stimulating economic growth and creating jobs. These proven results of venture capital investments are a tangible manifestation of the somewhat abstract goal of “capital formation.” 1 The National Venture Capital Association (NVCA) represents more than 480 venture capital firms. NVCA's mission is to foster greater understanding of the importance of venture capital to the US economy and support entrepreneurial activity and innovation. The NVCA represents the public policy interests of the venture capital community, strives to maintain high professional standards, provides reliable industry data, sponsors professional development, and ...
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