The SEC has provided very short notice of an open meeting to consider proposed rules under Title III of the JOBS Act. Title III of the JOBS Act amended Section 4 of the Securities Act to add paragraph (6), which provides a new crowdfunding exemption from registration under the Securities Act. This exemption is only operative after the SEC adopts implementing rules, which the JOBS Act directed the SEC to do by the end of 2012.  Now, more than nine months later, the SEC is first proposing the Title III rules.  The proposals will provide for the applicable conditions for the use of the Securities Act exemption, as well as address the non-broker dealer funding portals that are contemplated by the JOBS Act.  If the SEC approves the proposed rules, they will be subject to a public comment period.  FINRA will also have to engage in rulemaking with regard to the oversight of funding portals.  As a result, it is likely that we won’t see completed crowdfunding rules until some time in 2014.