A Web Service For Qualified and Accredited Investors

I just finished filling out a sixteen page questionnaire for an investment the Gotham Gal and I are making. I fill out this identical form about once or twice a month for various investments we make. Each time I get the form, I find a version I filled out previously in my archived email and copy the answers line by line. It’s complicated and I want to make sure I answer the questions correctly.

This form is created by lawyers to make sure that we are qualified and/or accredited investors. They also use this form to verify our tax and regulatory and compliance status. If you make an investment in a venture fund, a hedge fund, a private equity fund or a private placement, you will probably fill out a similar or indentical form.

Here’s the thing. I am literally answering the exact same questions again and again. I take great pains to make sure I answer them the same way each time. And it is a chore. I hate doing it.

Though the size of the accredited/qualified investor market may be small, I really don’t understand why there isn’t a web service where I can go, fill this form out once, and then certify that the answers are correct, and then simply auth with this service each time we make an additional investment.

If such a service exists, please point me to it and I will recommend it to the lawyers who handle these sorts of transactions.

USV requires our investors to fill out these same forms. When we close our next fund, we are going to hack together a web based system in partnership with our portfolio company CircleUp. But this isn’t really CircleUp’s business and they are doing this as a favor to us and our investors.

What we really need is a third party to offer this service to all accredited and qualified investors and we need the market to adopt it. It would make me and many others very happy to stop filling out these forms.

#hacking finance

Comments (Archived):

  1. Adrian Bye

    might be even better to drop the requirements as to who is accredited and who is not. people can make their own decisions

    1. inklenotrump

      well the SEC kinda did that but mostly hamstrung it.. hence the recent popping up of these type of syndicates https://angel.co/syndicateswherein Angles take 10-20% carry for their expertise in knowing which startups are going to get funded… I digress…The SEC now lets non-accredited investors invest up to some % of their annual income in crowdfunded stuff like the aforementioned syndicates or sites like fundrise or mosaic or whatever. problem is there is still a limit us poor folk are allowed to allocate (I don’t recall what the limit is exactly). It’s especially annoying for people like me who work in investing and want to be able to throw our pittance at good investments we see. luckily for the rich we can’t otherwise competition would emerge for actually good investments. (which no one wants or its for our protection or some other excuse, apparently).The point is the forms will still exist going forward.. which sucks fellow non-accredited investor.

      1. Raphael

        I believe the investment limit you’re referring to “for us poor people” is 10% of your annual income or $10k – the lesser of the two.

        1. inklenotrump

          yeah something like that.. and theres some other hoops to jump thru. I haven’t done the fundrise thing but after revisiting angellist syndicates I guess you still have to be accredited there as i think their commitment minimums must be higher than the average person can swing or some such.. and yes us poor people boo hoo me, Just saying the regulations, while a step in the right direction, still limit the general populace under some guise – probably protecting them from themselves or something. I just agree that with the OP that there shouldn’t really be the requirement. I mean the rules obviously don’t work. see madoff and other ponzies.

          1. Raphael

            It blows my mind that sophistication is based on income and net worth. I mean I understand the connection, but my problem with it is that people have much better access to information to base their decisions. Laws from the 1930’s are obviously mostly obsolete. These laws are just a modern hindrance, and it just increases the wealth gap. Success is relative, a 10x on $100 is just as awesome as 10x on a $100k.

        2. HerwigK

          Actually its different based on if you earn more or less than 100k. For the majority that fall into the LESS category, they are limited to 5% vs. the 10% in the more category. On the bright side its based on your net income or net assets, whichever is higher. At least those with large savings can finally start investing it. Based on current proposed rules by the SEC.

          1. ShanaC

            this needs to be simpler

          2. HerwigK

            I believe they are still taking comments! We can only hope the SEC actually reads them. http://www.sec.gov/cgi-bin/

    2. fredwilson

      well, yes. for sure. but it won’t happen unfortunately.

    3. LE

      Actually they can’t. Because the rest of responsible society is left to clean up the mess. And you have to prevent people from their folly. Same reason you don’t overfeed fish (remember this from when I was a kid about how they apparently will just keep eating).But then again there isn’t anything in place to prevent people from gambling away their money and/or using their money for a million of the wrong things which cause others to have to bail them out. But two wrongs and all of that.That said I think it’s a good idea. (Having a check on who can invest that is). Because by and large most people are to stupid to be allowed to get involved in this type of investing. I’ve spoken to a number of people who are convinced they should leave their solid secure well paying job to take a gamble job with a startup. The hype is that thick.

      1. Adrian Bye

        given your logic people shouldn’t be allowed to vote either.if you feel people aren’t smart enough to invest their own money why are they smart enough for democracy?

        1. LE

          “why are they smart enough for democracy?”Who says they are? (Besides that’s just grandfathered!) You’re not saying that people who vote actually come to well thought out informed decisions as far as who to vote for as opposed to, say, simply relying on what others and/or thought leaders have told them to think?I’m reminded of this when I watched a zillion Kennedy documentaries. One in particular asked people different opinions on Oswald, CIA, Mafia, Johnson, coverups etc. And in the end you got a big survey of basically not what people had concluded from the facts but what people concluded based on biased information that they were subject to and had read somewhere. In other words someone elses interpretation of the facts.Separately I actually benefit in what I do from more money being invested in startups. That’s right it benefits me and is good for me and this is the way I think about all of this.As far as people having a clue it reminds me of when Cramer (who I have watched occasionally) or someone else tells people to “do their homework” on a stock. As if.

    4. Richard

      SEC can’t even keep up with Insider Trading.

    5. pointsnfigures

      never going to happen. it requires govt to give up power and control. govt’s don’t do that.

  2. Mark Essel

    Pain + $$ = Market Opportunity.Best of luck with it Fred, it’s a good pain to have.

  3. Mark Essel

    Fred World Problems

    1. fredwilson

      if it was just me, i would not have written this. it may be a small market. but its a lucrative one.

      1. Guest

        One of my friends in Boston has just started to work on a Fund Administration platform for the hedge funds sector (11,000 of them globally according to him) so this post sounds like it segues with what he’s doing.There are tools which the large IFA networks use to verify and authenticate investors but those are institutional-scale and tied to the Tier 1banks.Most Web 2.0 offerings for the hedge funds are to do with either:(1.) Processing volumes of “Big Data” for Analytics modeling;(2.) Creating community a la Sum Zero, invested in by Winklevoss brothers.A Fund Admin platform for the sector hasn’t (as yet) been developed but my friend is working on such a utility.I’ll tell him to read this post and maybe get in touch with you if it fits with what you seem to be after.

        1. Guest

          In Web 1.0 my team invested in EO, the platform that enabled retail investors to participate in IPOs. That had a neat investor form-filling and verification process.However, the Web cycle changed shortly after launch which affected it. The founders later sold the core technology to advfn.com.

      2. LE

        There are many things that are similar. Another that comes to mind is mortgages. Or any kind of bank loan. And if you go to a new doctor you still have to fill out a million forms.With respect to college applications the “common app” took care of a similar problem (with a much larger market of course).https://www.commonapp.org/L

        1. ShanaC

          I think the medical one will happen sooner rather than later due to provisions in ObamaCare about repeat hospitalization penalties for hospitals.The common app may have made getting into a good college more difficult, and also have made their networks slightly more of a commodity. You might as well apply to all the schools of a certain level if you can afford the fee (or get it waved)

          1. LE

            If it is trivial to apply to colleges then what we really have is a system where the college picks you as opposed to you picking the college.And then, as a general rule you have a system where the person who looks good on paper has an advantage (they always did but now the curve has moved).What’s funny is that this in a sense resembles (get this) the soviet system where (I thought) the state decided what you could do and what career you would have.

      3. Kasi Viswanathan Agilandam

        And that my friend is called “Fred World” … orelse he would have said … Fred’s problem…. 🙂

        1. Mark Essel

          Spot on.

      4. ShanaC

        how much would you be willing to pay for this.

      5. JamesHRH

        totally agree.Value of time for accredited investors has to make this a slam dunk, even if it was a dedicated service bureau that filled in the forms manually for you.

      6. Mark Essel

        Not disagreeing in the least, but would love to share this particular pain.Trust is the key here. You want to automate it. Right now the trust is tied up in the paperwork and legalese. What institutions would you trust with all the information you have to provide to prove you’re an accredited investor?If banks can handle digital transfers, I don’t see why credentials can’t be handled the same way.When I swipe my credit card and scrawl a signature the retailer trusts my authorization. Paypal digital transfers provide an api handshake to approve transactions. Chrome and Apple store my username and passwords to a number of sites and services, again another example of trust and iterative identity proof.

    2. leigh

      Pet Peeve Sundays?

    3. Kasi Viswanathan Agilandam

      +1 Mark…. Happy New Year.

  4. arjunblj

    This sounds like something up AngelList’s alley.

    1. fredwilson

      yes, indeed

  5. Brad Gerstner

    Fred, excellent point. As a recovered securities lawyer, what we also need is sanity in our securities laws so that you don’t need to fill out 16 pages in the first place. While this form provides a “safe harbor” for issuers – it is insulting in 2014 that we actually use “income” and “net worth” to determine whether one is qualified to make a private investment. I would venture to say a young engineer at Etsy is more “qualified” to invest in your next fund or start-up than a doctor from Tampa. Best in 2014.

    1. fredwilson

      yuppppppp

      1. ObjectMethodology.com

        All someone would need is some support and backing then your request is easily fulfilled.

    2. Aaron Klein

      +100

    3. LE

      “I would venture to say a young engineer at Etsy”Why?First you are simply not going to get a system where people are evaluated the same way that college applications go (where actually a large part of it is numbers actually) based on a whole host of qualitative and quantitative metrics. That is a lot of work.Who exactly, that is where is the manpower going to come from to determine that the “young engineer at etsy is more qualified” [1] than the physician from Tampa (which brings back memories of the doctor in the movie “Boiler Room”).[1] What exactly makes you think that a young engineer from etsy, with a very limited view of the business world, is in a good position to make an investments such as these? Are there any figures on that group of people as a whole that succeed vs. fail. In a eco system where investments by angels that actually have experience, are typically represented as failing more often than not?

    4. ObjectMethodology.com

      Yep a real shame that you can have a brilliant person not qualify to invest based on some useless criteria.

    5. ErikSchwartz

      I’ll take issue with the “young engineer at…” qualifications.In my experience people (and I was one of them) who have only lived in a successful company in a bull market tend to vastly under appreciate the role of luck and market forces outside their control in a start ups success.

    6. ShanaC

      I would not trust most young engineers at Etsy, the same way I would not trust a doctor. Most don’t care enough o know how to do fundamental research.

  6. Raphael

    I believe sharespost uses something similar to what you’re describing, but I’d expect a persons situation to change from year to year. Unnecesary general solicitation fears.

  7. Neal

    CAIS does this for the investments through their platform

    1. fredwilson

      right. that’s the thing. it exists as part of turn key platforms but not as a stand alone thing

      1. Richard Rodman

        Fred, check out crowdentials. We have it as a standalone product.

  8. ErikSchwartz

    How much would you be willing to pay for such a service? It would have to be a lot because the audience for the service is smallish.Or it’s a feature for someone like angellist.

    1. fredwilson

      if i was building it, i would make it free and package it with a funds transfer service that charged a small fee on. i would add free fund investment accounting to it and then you would have something valuable and interesting for the accredited/qualified investor

      1. Robert Carbone

        My company CrowdBouncer has a patent pending on an automated process for that very solution, Fred. We saw early that compliance and funds transfer would be inextricably linked in the 506(c) ecosystem. We are in the process of seeking an escrow/e-payments partner to implement it. But our API-based accredited verification process is fully live.

        1. fredwilson

          a patent for that? really?

          1. Robert Carbone

            We are protecting what we can. It has been a non-trivial process to fluidly automate.

  9. Semil Shah

    Naval talks a lot of about standardizing all the documentation in and around startups, both to free up time and also to reduce redundant legal costs.

    1. fredwilson

      they are a logical choice to do this

    1. Richard Rodman

      I think this could too. Do you work for SRS? If so, you should have them contact me. [email protected]

  10. Yasaman

    Fred – Do u think DocuSign can help?

  11. stevewfindlay

    Fred – do you have a (blank) copy you could send? This could be one for us at http://www.invrep.coWe focus on everything after the investment is made…but could look at extending into everything after the investment decision is made…

  12. Josh Maher

    There are a few folks in this space – SeedInvest and SecondMarket come to mind first for me. Microventures sort of has this service as well. I’m sure there are others.

    1. Richard Rodman

      Crowdentials has this. Seen invest, second market, and microventures do what Fred is talking about. It’s a very cumbersome process.

  13. dgay07

    Sounds like the standard subscription agreement questionnaire. Luckily, we have an analyst that is tasked with it, but some of them are so onerous its ridiculous. It sounds like an electronic signature firm, such as DocuSign might be a good home to handle something like this where you can save answers from previous funds/investments. Perhaps they could develop standardized questionnaires based on type of investment. I have used CircleUp to peruse opportunities, but haven’t acted on any of them. My guess is you would still have to go through the standard documentation process if an investment takes place, correct?

  14. Tom Labus

    Fred, you’re so scrupulous in your approach to this and then I think of the SAC trial starting today and their “willful blindness” to insider trading regs.

    1. pointsnfigures

      They didn’t work really hard to find the banks colluding on LIBOR back in 2008….

  15. falicon

    On a related note, I’ve been fingerprinted (for background checks) and forced to take the same “youth protection” program about a hundred times…they are really important and good things to require, but it’s *crazy* that none of these organizations talk to each other or share resources (it’s the same fingerprinting place each time, but they are not *allowed* to just share the record with each organization — I have to physically go there each time)….on the plus side, I have about a 100 different mobile apps i can take and share a photo from though…

    1. Eddie Wharton

      social meets local meets mobile meets sharing economy: going to be the next big thing

    2. LE

      “but it’s *crazy* that none of these organizations talk to each other”They should just be, like, you know “yeah, Kevin, he’s a goodfella” and just waive you on to the table up front with Lorraine Bracco. Great steadycam shot.In all seriousness the reason they probably don’t, in addition to the fact that it would take work to coordinate, has to do with either “cya” or “not on my watch” attitude with respect to the risks involved.

      1. falicon

        =)I get the reasons behind it…I just think it’s one of those crazy things that hasn’t been solved yet…I can’t even auth. the release/reuse of it myself.Just one of a million crazy realities that still exist in the world…

  16. Richard Rodman

    My company, Crowdentials verifies accredited investors and keeps the record on file for 3 months. Also, we keep the answers on record so you simply have to resubmit the form without typing the answers again (one click) and it’s on file for another 3 months. Send me an email and we can talk further – I think we have exactly what you’re looking for. [email protected]

    1. LE

      What steps do you take to secure the information you collect. (Please be aware that if you give me an answer that sounds boilerplate marketing or technical jargon I will take issue with it for sure).

      1. Richard Rodman

        All info on our database is encrypted and all passwords are salt and hashed; everything is beyond current web security standards. We are also hosted on the latest Amazon EC2 and RDS servers. We have the security level of a bank’s online portal.

        1. LE

          Richard, who does, as only one example, your penetration testing and how often? [1]Security is something that has fooled the best and the brightest.And you are sitting on a trove of valuable data for any hacker.Checking your about page I’m not seeing anyone with security expertise [2] and even if I did I would still ask the same questions. It is a full time job keeping systems secure.This is one of these things that everyone thinks they have all figured out and under control. But they don’t.[1] http://en.wikipedia.org/wik…[2] And I don’t even see anyone who would even know or be able to tell the degree to which someone was qualified in this area.

          1. Richard Rodman

            We have had outside consultants help with all of this. Maybe we should talk further – [email protected]

          2. Richard Rodman

            We do penetration testing on the site itself but as for the server (database and hosting) we trust Amazon to handle security.We also monitor server logs for all malicious activity.

  17. Eric Fleischman

    What you’re describing is a pretty classic DocuSign sort of use case. Lots of folks have done stuff very much like this on top of the platform in other places.Happy to help if you want to give it a go…~EFull disclosure: I work @ DocuSign

    1. ShanaC

      It isn’t the same as the rest of the forms though…

  18. Hunter Walter

    I became familiar with this issue having a personal interest in startups and speaking to many established investment managers and/or vc principals that were still apprehensive about the JOBS Acts’ regulation changes.As a result, I was introduced to the founders of a software company called Crowdentials and saw so much potential in their automated verification service (not to mention attitude and philosophy) that I joined their team shortly after the September 23rd start date.Check it out: http://www.crowdentials.com // [email protected]

  19. June

    A friend of mine just started up Accredifyhttp://accredify.co/

  20. Ana Milicevic

    Something like this would, amongst other things, be a great addition to Angel List.

  21. Richie Siegel

    hello sign?

  22. pleppik

    There’s lots of other places something like this would be very helpful.As a parent, I’ve often wanted the same thing for my kids’ immunization forms, emergency contact info, etc. Especially when signing up for summer activities, we wind up filling out almost exactly the same form over and over again. Sometimes it’s exactly the same form for the same organization, but they insist we fill it out separately for each class/week/activity.Someone needs to stop the madness!

    1. lance

      KidsLink.

  23. John Revay

    I fill your painI use to work in the back office of a VC firm. I had a similar beef with filling out Rule 144 restricted stock filings…..This was almost 25 yrs ago….and we would have them typed on a typewritter, this was before there were PDF that you could template.At the time, I found windows based forms program that we created a template with, it made life a little easier – there was still a lot of manual work/entry.

  24. Michael Taus

    We’re evaluating 3rd-party services like this for CrowdStreet (http://www.crowdstreet.com), including:SecondMarket – complete but expensiveVerifyInvestor – investor can redact non-essential info when they upload docs)CrowdBouncer – has an APIAccredifyThe security and integration issues are interesting, in part because these companies tend to view Issuers as their customers and are often reluctant to provide details to platforms/portals.I’d bet these issues will be worked out this year, at which time the survivors will be revealed.

    1. Richard Rodman

      Crowdentials does all of this without using personal financial information – No IRS docs or Tax Returns

  25. Dave

    Accredify seems like a good tool and a few of these companies are springing up. In the meantime, perhaps you could send a quick email to Jason Mendelson. Between the two of you, I’d guess you could get the leading Silicon Valley firms to at least agree on a standard form. If you had Gunderson, WSGR, Fenwick, Cooley, DLA on board, almost certainly you’d then be able to get the key Boston firms on board as well. You’d have pretty significant market share for both financings and VC funds among those firms. Open source the form like many of the Series Seed financing documents and you’d have pretty solid adoption.If you had the same form agreed to be accepted then you’d have a perfect DocuSign use case. The form would be easily re-usable, you’d generally only need to update it once a year at most and a click to agree signature would work. If it is just a check box income in excess of $X then it probably doesn’t even need to be updated that often. It might not be as good as a web service, but it could be pretty close. Put the form in your Box or Dropbox acocunt and it would be easily shareable.

  26. William Mougayar

    Another one of those processes that haven’t evolved with the web. It feels ripe for AngelList to offer as a service. Maybe http://crowdentials.com/ (mentioned here) is close to what you’re looking for.

  27. Jor Law

    Fred, as a active corporate/securities attorney and an angel investor, I saw this gap as well. I helped launched VerifyInvestor.com to provide accredited investor verification for JOBS Act Title II compliance, and expect to expand to automate more of the subscription process. Most lawyers and law firms we’ve demoed the product to have thought we were best in class in terms of simplicity, privacy, security, legal compliance, and value.

  28. sigmaalgebra

    How about just automate the completion of the form?There are several potential solutions that varydepending on what the inputs and outputs are, whatsoftware tools are to be used, and how muchautomation is desired.I don’t know the details of the form, etc, but hereis a hypothetical example:D. Knuth did his mathematical word whacking systemTeX. So, basically it’s just some word processingexcept it is just excellent at getting ‘display’math expressions looking good.TeX is well tested and has been heavily used withgreat success: Knuth wrote TeX for typesetting hisbooks in his series ‘The Art of ComputerProgramming’ (TACP). In addition, TeX (and therelated macro package LaTeX) has now long been theunchallenged international standard for wordprocessing in more mathematical fields. So there isno shortage of good looking TeX output! For a tinyexample, easy with TeX and tough otherwise, can seethe image at the end of my post http://www.avc.com/a_vc/201…where I show that there are infinitely manyinfinities via a simple argument standard inaxiomatic set theory.In addition TeX has a powerful macro facility andsome other good features. Output can be to, say,PDF. And ‘data’ input can be from a simple textfile. So, e.g., it’s easy to use TeX to generate’personalized’ form letters where the basic letteris in one file of the usual TeX input and thepersonalization parts are in simple text files readby TeX while processing the TeX input file.So:(1) Use TeX to reproduce the blank form, if this iseasy. Then for each place on the form where inputis needed, assign that place a name. Then in theinput file, have values for each of the names. Washit all through the TeX EXE program and get out thePDF which might be enough. The usual TeX output isto a TeX-specific ‘device independent file’ (DVI),but there is at least one standard program toconvert DVI to PDF; that’s how I send FAXes toCongress — write a letter in TeX, convert to PDF,and use the Adobe Acrobat program to ‘print’ the PDFto the FAX printer and then use the standard Windowstools to send the FAX via my old $25 FAX modemconnected to my voice phone line. Note: Also withthat FAX modem a little three line or so editormacro can grab a phone number from any line ofessentially any text file and dial the number bysending the ‘attention’ code to the FAX modem.(2) Starting with a printed paper form, use a rulerto get the coordinates of each of the input fields.Turns out, in TeX can put text at any place on thepage specified by just coordinates. E.g,, I do thisto put a decorative border around the content ofeach foil of a ‘foil deck’. So, have the text inputfile have pairs of (a) the coordinates and (b) thecontext of the input for the field at thosecoordinates.Then could feed the official form through a printersending the TeX output to print on the form.Second, could scan the official form and have TeXread it in and overlay your input as the printingwith output to paper or PDF.E.g., if I have a technical paper in TeX with afigure from, say, Excel or PhotoDraw and want toannotate the figure with text, possibly mathematicalexpressions, from TeX, then I use the ability of TeXto put any of its output at any coordinates on thepage to place the annotation just where I want it onthe figure. To find the coordinates, I have alittle TeX macro that puts a grid on the figure,look at the output on the screen, and then enter thecoordinates for each piece of annotation. Simple toprogram; simple to use; works fine. And I get thefull power of TeX to write the annotation which,then, looks as nice as the rest of the TeX output –especially important for annotation with somemathematical notation, e.g., subscripts, exponents.(3) Scan the paper input form into PDF and use thefacilities there, if sufficiently powerful, toautomate bringing in the input data and placing itwhere needed on the form.(4) Another approach would be to scan the form to,say, a PNG file and write some HTML to display thescanned image on a Web page. In that HTML file,call it pre-HTML, have some tags unique to that filethat identify the fields to be filled in. Thenwrite a little program in, say, Rexx or any languagewhere string manipulations are easy, to read thepre-HTML file and the data input (pairs of the tagsand the desired corresponding values) particular toa user, and write out the corresponding HTML. Thendisplay the HTML file in a Web browser, and use thebrowser’s ability to print to print the form.Downside here is that the output is just to an HTMLfile or to a printer and only by manual work foreach page. There are some ways to automateinteraction with a graphical user interface (GUI)program such as a Web browser, but these ways areclumsy to use.With a little care, could have nearly a one commandway to get all the work done. So, if the userspecific input is available, then one command to ascripting language (e.g., Rexx, Microsoft’sPowerShell, whatever on Linux), could generate thedesired output on paper and have it printed as onePDF file per page and have those files pulled into afile, as ‘attachments’, of e-mail with the standardInternet Engineering Task Force (IETF) requests forcomments (RFC) multi-media internet mail extensions(MIME) and send the e-mail via post office protocol3 (POP3) with a clean ‘paper trail’ of what wassent. Of course the software could also place datesas desired, pull in a graphics file of a scannedsignature, etc.A lot of such techniques for automating completingforms have been used over the years. Once (I shouldlook for it again) I wrote a little program in theinterpretive language Rexx to use a daisy wheelprinter to complete a USPS Express Mail form. So,for each field on the form, I used a ruler to findthe coordinates of the field, and my program read aninput file with the pairs of (a) the coordinates and(b) the input at those coordinates. To get reallyclear printing on the several carbon copies, I setthe printer to use ‘bold face’ which means theprinter just hit each character several times. Witha metal daisy wheel, got some quite clear typing onthe carbon copies!There are many ways to automate completion of officeforms, without using the Internet or a Web site!Oops, I forgot one more: When my HP B/W laserprinter finally died, I got a Brother B/W laserprinter as a replacement. Well, the HP honored acute language HP Printer Control Language (PCL), andit was easy to use Rexx to generate the escapesequences and to send them to the printer via the PClogical printer port LPT1.So, I had a simple printer utility program, writtenin Rexx, that would make a nice presentation onpaper of a simple text file. Alas, the Brotherprinter did not support PCL in a sufficientlycompatible way. So, I got out the Windows tools forputting nearly anything on paper and wrote anotherversion of my little text file printer utility.The Windows tools are mostly their ‘Graphical DataInterface’ (GDI) or some such. A start ishttp://msdn.microsoft.com/e…and files close in the Microsoft MSDN documentationtree.It would be fairly easy to modify my Windows programto read a text file with (a) coordinates and (b)text to place at those coordinates and also read afile of a scanned image of the form and send allthat data to a PNG file or a printer. With a littlemore effort, could send to a PDF file.Generally with the usual programming tools on a PC,there is no shortage of ways to put marks on paperor in a PNG file.Of course with my solution here, a Web site is notcrucial. But it may be that a Web site solutionwould have some value as a business.Another point is that, really, nearly no one wantsthe stupid form and, instead, wants to pull the datafrom the form and put it into a relational database.So, a closely related issue is how for the companyreceiving the form to bridge from the form to thedatabase input.So, the output of any software to generate a ‘form’should also generate, say, a file to be sent andeasily read to populate a relational database. Yes,might want some ‘certification’ of the file.

  29. jortpossel

    I thought about this opportunity in a broader sense, when having to fill in my visa papers for the millionth time with all the same info: name, contact details, social security #, work experience, education etc etc. Hundreds of fields. A mechanism where one would create an extensive profile once that can be used to pre-populate forms would help many people.

  30. pointsnfigures

    hate that form. not a hacker, otherwise i’d hack it. there are lots of wrote/duplicate legal forms that could be streamlined this way.

  31. Kasi Viswanathan Agilandam

    I (you) am a king within my (Your) kingdom not everywhere .. …Just 2-examples which comes to my mind immediately …good one’s though…Case-1: 16-years after finishing my Ph.D in MRI …some one in software industry from Canada … supposed to be the CTO of a reputed medical software company trying to establish their off-shore development center in India…asked me…can you explain me how MRI works?I explained him sincerely for 5-minutes …because I was looking for a job in his software company and he was interviewing me …Case-2:I still remember the very similar question by one of the Prof during my Ph.D Viva…Can you explain to me in simple terms what is your thesis is all about … I tried and tried and tried ….could not finish it.After the viva my guide told me ” You should have told him …-read the fucking thesis-…in one simple sentence”…

  32. HerwigK

    Fred,I foresaw this exact problem 3 months ago as I was researching the JOBS act, which Title II had a major implication in.I agree that this is not CircleUp’s problem. My service, Accredify, is completely focused to serve the investor. We make the accredidation process easy because we verify with the IRS for you, and then give you an online certificate to share. To take it to the next level, we are developing an API that shares this information with portals via just one click.We will also be working with all of America as we comply with the SEC regulations for non-accredited investors to make it simple and easy for anyone to begin investing in startups.It’s a simple solution for an annoying, but important problem.

    1. ShanaC

      This is sort of awesome – do you also automate the forms

      1. HerwigK

        It’s automated and takes about two days until we can verify you for certain. We are considered what is a “reasonable step” as defined by the SEC for entrepreneurs and portals to verify investors.

    2. Tereza

      That’s awesome.

    3. @MartyCrampton

      Checked this out t’other day – Seems useful (not the leasat bc it seems simple 🙂 What sort of fees are you looking at – Portal side vs Client side?

      1. HerwigK

        Our API will be similar to Facebook Connect, where our users (who pay an annual membership) will choose to share their basic information (name, email, Accredited status, and certificate expiration) when they connect to a portal that offers our “Connect with Accredify” button. The API is free for portals, but again, portals will only receive basic information when and if our users choose to give it to them.

  33. naval

    Hi Fred – we already offer this for free to all investors on AngelList and make it portable via the API. It’s 506b and 506c compliant. We haven’t blogged it or added a user-facing component to it (i.e., one-click export), but that’ll all be coming this month.

    1. Mordy Kaplinsky

      I was going to suggest talking to AngelList about this but was looking through the comments to see if anyone suggested that already.

    2. naval

      We just pushed a free and open web service for Accreditation live:https://angel.co/accreditationIt's 506(b) and 506(c) compliant. You can accredit even if you’re not using AngelList for a closing. We will save your accreditation and you can share it for other financings with one-click, via a share link or via an API. More here:http://www.feld.com/wp/archhttp://techcrunch.com/2014/…Feedback welcome – thank you.

  34. Alex Herder

    Check out Solid Gold Unicorn, they build products (really well) for a flat fee. http://www.solidgoldunicorn

  35. Flip Tu

    Hi Fred — check out Seed Invest — http://www.seedinvest.com. They have a standardized accreditation verification process complete with questionnaire, real-time identity verification, etc.

  36. Dan Magnuszewski

    Check out CrowdBouncer (http://crowdbouncer.com) – they’ve been in the space for a while and have built the the system you’re looking for. They are a part of Z80 Labs in Buffalo – ask Jordy about them!

  37. Kiran Lingam

    SeedInvest has been doing this for months for free (including for GothamGal’s Scoot Networks – see http://www.gothamgal.com/go…. Once an investor completes our verification process, the investor will receive a certification letter from a broker-dealer that he/she can reuse anywhere.Getting verified is easy and can be completed in less than 5 minutes. We are electronically integrated with the IRS for net income verification and offer automated processes to check net worth via a lawyer/CPA certification or document upload.Check out gs.seedinvest.com/aiv for more information.

  38. Alexander Ainslie (@AAinslie)

    Fred, this should/could be part of a broader #VRM platform. (cc @dsearles)

    1. ShanaC

      You can’t cc someone unless they are already in the thread.

      1. Alexander Ainslie (@AAinslie)

        Doc Searls will likely get pinged via google notifications.

  39. Richard Rodman

    Fred,You have to use Crowdentials.com – We don’t use personal financial information and we keep the file on record for later use. Our solution solves the EXACT problems you’re facing. Please email me to speak further [email protected]

  40. Jay Turo

    Fred – VerifyInvestor.com does this.

  41. Jor Law

    Fred, as an active corporate/securities attorney and an angel investor, I saw this gap. I helped launch a service (www.VerifyInvestor.com) that makes JOBS Act Title II compliance easy. Most law firms we’ve demoed it to have thought we were best in class for ease of use, privacy, legal compliance, and value. We’ll be looking to expand into automating the entire investor questionnaire process.

  42. Adam Nash

    If this was an open standard, then any forward-thinking financial provider could offer support for this. I’d definitely be interested in help supporting a platform like this, both as a consumer & provider.

  43. John Sechrest

    I think that seedinvest.com is aiming at this problem

    1. Kiran Lingam

      SeedInvest has been doing this for months for free (including for Gotham Gal’s Scoot Networks). Once an investor completes our verification process, the investor will receive a certification letter from a broker-dealer that he/shecan reuse anywhere.Getting verified is easy and can be completed in less than 5 minutes. We are electronically integrated with the IRS for net income verification and offer automated processes to check net worth via a lawyer/CPA certification or document upload.

  44. SashaA

    Hi Fred. Completely understand the pain of doing this, especially being a securties lawyer myself. That is why my startup AlumVest, a new crowdfunding platform matching alumni with entrepreneurs, will offer this service through an API. This will be an easy one time process that a potential investor (individual or entity) will be able to complete and is compliant with the new SEC general solicitation rules. If you or anyone else has any questions on this service, please feel free to email me at [email protected]. I’ll be happy to introduce you to our partners. We plan to go live by the end of January. Thanks

  45. alonymous

    We were going to build something similar, but there are TONS of folks working on this problem. For our customers, and ourselves, the plan is to use whichever service wins market-share, or build a similar solution once a standard (at least for crowdfunding) is reached.

  46. Cynthia Schames

    I believe SeedInvest does this, @fredwilson:disqus

  47. ctw123

    There is a support company for AI being formed in Germany right now that will have this in-built as a feature. alas for once Europe is not behind the US… http://www.asset-metrix.com

  48. S Ryan Meyer

    Fred,This solution is perhaps overly simplistic, but based on my read of the SEC’s current, promulgated rules on general solicitation (i.e., not the more strict ones that have only been proposed), a simple oath administered by a notary public attesting to the specific accredited status of an investor will satisfy the “reasonable steps” bar that the SEC set.I’ve debated this publicly at a conference with some extremely talented securities lawyers and have yet to be convinced that this is not a viable option, as it puts the legal responsibility back on the shoulders of the investor claiming to be accredited.Even though we’re not yet generally soliciting investments for our portfolio companies on my platform, we have an interesting use case coming up with a graphene solar cell startup from Caltech with which we’ll implement the above regime as a backup to accidentally crossing the general solicitation line.The SEC has stated that they won’t accept self-certification for general solicitation cases, yet the act of notarizing an oath attesting to one’s status as accredited seems to go above the ticking of a few boxes online to which I believe the SEC was referring.I’d love to hear commentary on how flawed others find this approach to be…

  49. Lee Blaylock

    Agreed it is a pain. I’d be a bit surprised if Docusign can’t do this. Our attorneys and I use it for all docs to my preferreds and it is an excellent service.

  50. Richard Rodman

    Fred,I just wanted to let you know that your blog post was quoted in a WSJ post about us.http://blogs.wsj.com/ventur

  51. pointsnfigures

    people should be free to do what they want with their own money regardless of how much of it they have.

  52. pointsnfigures

    I don’t think so. If I had a lot of expertise in something, and could see the impending world before others-but not the means, I could take advantage of that by investing. Success would turn me into a have.

  53. ShanaC

    Except hurt me. Which is a complicated notion