[HN Gopher] Investing in Startups by Passing the Series 65
       ___________________________________________________________________
        
       Investing in Startups by Passing the Series 65
        
       Author : 18nleung
       Score  : 89 points
       Date   : 2021-10-13 17:57 UTC (1 days ago)
        
 (HTM) web link (www.natecation.com)
 (TXT) w3m dump (www.natecation.com)
        
       | funshed wrote:
       | I loved the get-out clauses. Though being from UK I am a little
       | confused, you need authorisation to buy shares in a SME in the
       | US?
        
       | jsjsbdkj wrote:
       | If you're a college student and you put 1k into your friend's
       | startup, is there a risk that's actually a negative signal for
       | future investors? Do investors in a real series A want a cap
       | table that has a bunch of friends and family chipping in a grand,
       | or are they just going to ask to wipe the slate clean?
        
         | rmah wrote:
         | Your small investment is not, by itself, a negative signal.
         | However, a lot small investors can lead to headaches down the
         | road as once you pass the 99 investor threshold more
         | regulations apply. Also, dealing with a bunch of investors is a
         | PITA.
        
           | [deleted]
        
         | enra wrote:
         | It doesn't matter much if the company is generally VC fundable
         | or doing well. Ideally you have investors that can help you and
         | the company, but if you have few friends there too, no-one
         | should care.
         | 
         | We raised some money from friends, family and angels at pre-
         | seed, and at seed & series A, the VC didn't have single
         | questions the cap table.
         | 
         | But the companies should have legal counsel, and try to use the
         | standard YC SAFEs not to give people some weird terms. Also as
         | a startup founder, you should make clear to family/friends/non-
         | professional investors that investing in the startup is very
         | risky, and as a minor investor they don't really have any
         | rights as an investor, except hopefully have some returns for
         | their investment.
         | 
         | There is some horror stories where someone gets their dentist
         | as an investor and they start calling you every week about
         | updates or show up at the office to chat about the business
         | plan.
        
         | funshed wrote:
         | Good Question..
        
           | mhb_eng wrote:
           | My experience with this, though this may not be the consensus
           | view, was that participation from friends/family was
           | generally a good sign, since founders clearly believe in the
           | business to the point of pitching their friends to invest
           | (and getting deals closed shows some evidence of sales
           | ability).
        
       | vmception wrote:
       | The other aspect of this is that the door is open for an
       | accreditation-specific test to become approved.
        
         | gahays68 wrote:
         | Check out Doriot.com / they're the first to submit an
         | application to the SEC to become approved and have a product
         | already in market
        
           | LurkingPenguin wrote:
           | Elizabeth wears turtlenecks daily and her startup has a star-
           | studded board of directors with little relevant experience in
           | its industry.
           | 
           | You invest as much as you can access through a credit card
           | cash advance because:
           | 
           | a) FOMO
           | 
           | b) YOLO
           | 
           | c) TMI
           | 
           | d) TL;DR
           | 
           | e) ABCD
        
             | slowhand09 wrote:
             | f:WallStreet Bets
             | 
             | *your post wins the commentary for this entire thread.
        
       | cortesoft wrote:
       | Matt Levine has written about the problems with opening up this
       | kind of investing to everyone.
       | 
       | One of the major differences between earth stage startup
       | investments and normal public companies is that there is not an
       | open market. Startups can choose their investors, and don't have
       | to give the same price to all investors.
       | 
       | So yes, if you get accreditation, you will be able to find a
       | startup to invest in... however, it isn't going to be the best
       | startups, and you aren't going to get the same valuation that big
       | VCs get.
        
       | dogman144 wrote:
       | What's the minimum possible investment you'd need to be taken
       | seriously by a startup - 5k, 10k, etc?
       | 
       | What rounds would you look at mostly? Assuming it's gotta be
       | seed-ish unless you're very liquid.
        
         | lmeyerov wrote:
         | As a founder, you don't want tons of small checks because of
         | legal complications (> 99 entities on your cap table) and not a
         | good ROI on your time initially + ongoing. A workaround is
         | bringing in someone to run a syndicate on AngelList or some
         | other bundling, making it their focus vs yours, and condensing
         | to one entity.
         | 
         | The result is, as an individual investor, you can focus on
         | those syndicates. Two benefits are you can spread risk by doing
         | a wide variety of small investments, and while following more
         | experienced individuals.
        
           | themanmaran wrote:
           | I've seen that changing a bit recently with the AngelList
           | Roll-up vehicle[0].
           | 
           | It's almost like crowdfunding for seed rounds, but still with
           | $5k - $20k kinda checks. But it helps out a lot with the
           | legal side of things, so you don't need an investment
           | agreement with a dozen different investors.
           | 
           | [0]-https://www.angellist.com/ruv
        
         | toomuchtodo wrote:
         | It really depends on the startup, their traction, and your
         | relationship with the founders. I've had folks ask for
         | $10k-$20k for a seed round (the line between angel and seed is
         | very blurry imho) with zero traction and a rough idea of the
         | product market fit with a barely functioning MVP, and another
         | team I spoke with wasn't talking to anyone without $100k to
         | invest. Once you're past the seed stage, unless you're
         | connected or an employee, it's $1MM+.
         | 
         | I focus on seed stage as I'm seeking high risk high return
         | exposure for this part of my portfolio (and I'm not liquid
         | enough to participate without investing in a fund for Series A
         | on, unless I'm leveraging as part of a transaction).
         | 
         | (n=1, YMMV, accredited investor)
        
           | dogman144 wrote:
           | thanks!
        
             | toomuchtodo wrote:
             | Happy to help.
        
       | jedberg wrote:
       | > To be completely honest, in practice, this whole process of
       | accreditation -- at least right now, for the purposes of startup
       | investing -- was sort of unnecessary. As a relatively cash-poor
       | college student, I don't have much investable capital to begin
       | with
       | 
       | I mean I guess it was a fun learning experience, but I'm not sure
       | why they would go through the trouble.
        
       | atlgator wrote:
       | I've considered getting my Series 65 for this same reason, but my
       | concern was how it would affect my other investments. e.g. your
       | typical low-cost brokerage accounts with TD Ameritrade, Schwab,
       | etc are not available for professionals. In fact, it seems like
       | everything costs a lot more if you are a licensed professional.
        
         | bertjk wrote:
         | Does passing Series 65 automatically make you a professional
         | for these intents and purposes?
        
         | slowhand09 wrote:
         | This derails any thoughts I had re Series 65...
        
       | jackcosgrove wrote:
       | I thought the name of the game in VC was investing in 20+
       | companies and seeing what sticks. You would need enough money at
       | that point that being an accredited investor would be a foregone
       | conclusion according to the net worth standard.
       | 
       | Investing several thousand here or there on one or two companies
       | seems incredibly risky, riskier than what the pros are willing to
       | tolerate.
        
         | tedmiston wrote:
         | Correct. Much better idea statistically to just throw it into a
         | good index fund if your goal is returns.
         | 
         | Perhaps it could be useful if the goal is learning oriented.
        
         | dbish wrote:
         | Yes, I'm seeing a lot of younger people trying to play the
         | angel investor game without the capital and without realizing
         | many angels don't make reasonable returns but it doesn't matter
         | to them because it's play money and more a chance to support
         | new ideas and learn about things. Personally, I put aside an
         | amount I want to angel invest every year and assume it's burned
         | but I really couldn't afford to do that in a responsible way
         | until I was well beyond the accredited investor minimum point
         | (in yearly income).
        
           | browningstreet wrote:
           | In regional hubs, a lot of the angel networks are retired
           | people. Most of them, in my experience, are playing at being
           | technologists or investors. They usually made some money in
           | more traditional business endeavors. Usually gets a bit of
           | traction in the local government / business lunch / community
           | innovation scene.
        
         | vc-doggie wrote:
         | Absolutely, this.
        
         | cbtacy wrote:
         | Yup. It's important to understand how the Power Law Curve
         | applies to early stage investing.
        
       | vincentmarle wrote:
       | > found, however, that there was an "internet adviser exemption"
       | for advisers that give advice entirely through the internet. That
       | sounded like an exemption I could qualify for -- I would just
       | have to commit to not giving any face-to-face investment advice
       | 
       | One thing I didn't understand from this article is what "giving
       | investment advice" has to do with being an accredited investor
       | and investing into startups. Can someone clarify that?
        
         | gregshap wrote:
         | Investing in startups generally requires being an accredited
         | investor. To be an accredited investor they need to pass the
         | Series 65 test and get licensed. Licensing can be state or
         | federal, but federal is generally more convenient. Federal
         | registration usually requires significant assets under
         | management which the author certainly doesn't have, but the
         | "internet adviser exemption" allows them to register federally
         | (SEC) without the $ minimum.
        
         | dragonwriter wrote:
         | > One thing I didn't understand from this article is what
         | "giving investment advice" has to do with being an accredited
         | investor and investing into startups. Can someone clarify that?
         | 
         | The article addresses this: the SEC accredited investor
         | classification has several ways to qualify, the older ones are
         | variants of "rich enough to presumably know what they are
         | doing" and the newer ones added are "has one of a specified
         | list of professional licenses/certifications that directly
         | relate to knowing what they are doing with investments", and
         | the particular one that the author chose to pursue for that
         | purpose was related to giving investment advice.
        
       | Projectiboga wrote:
       | There is still a catch, any firm using a Regulation D exception
       | has to go public if their shareholder total goes over 500. The
       | loophole is that they could require a minimum amount and for the
       | smaller amounts to join together into their own fund.
        
       | iammisc wrote:
       | Great writeup. Been thinking of doing the same thing.
       | 
       | > the unspoken secret is that accreditation -- at least when
       | investing in individual startups, and especially if the founder
       | is a good friend of yours -- is just a box you can check that
       | nobody verifies
       | 
       | I've heard this as well, and it's a very sad thing, because it is
       | one of those 'secrets' that if you knew, it'd open up a lot more
       | opportunities for you. There are few 'secrets' separating the
       | rich and poor, but this is unfortunately one of them.
        
         | vmception wrote:
         | The legal consequence isnt on you, its on the company selling
         | shares. So just like the Texas law, it deputizes everyone else
         | to shut out poor people instead of being a prohibition from the
         | state directly on the poor person. In practice that means just
         | never talking to poorer people about opportunities, and letting
         | them figure out that they cant even raise capital because none
         | of their friends are accredited. Just American things.
         | 
         | Its Super effective!
        
           | czbond wrote:
           | You act like startups are some "keep poor people down
           | scheme". It is because startups are incredibly high risk, and
           | they will most likely lose their money. "Poorer" people can't
           | stand to lose 8/10 bets they place in most cases. Only in the
           | past 10 years with bubble money, and bubble VC exits are
           | Silicon Valley startups seems as 2/10 gold mines. Before
           | that, they were few/far between with a lot of failures.
           | Startups are a failure game.... because their default mode is
           | "fail".
           | 
           | Also note, outside of SV - the rate is nowhere near 2/10
           | billion valuations.
           | 
           | Making sure an investor has financial acumen helps founders
           | focus because it is hard enough raising money from
           | angels/VC's in $10k+ amounts - imagine if you only raised
           | $100-$1k per person. Egad! Crowdfunding might be an exception
           | to this - but it is fairly new.
        
             | vmception wrote:
             | I don't think anyone specific is responsible for this
             | exclusionary-by-class system, I do think there are some
             | opportunists that perpetuate it, and for that just look at
             | the discussions and comments over the accredited investor
             | regulations hosted on the SEC servers.
             | 
             | People shouldn't need to ask for permission to fail.
             | 
             | In case it isn't clear, I am not saying startup investing
             | is a golden ticket, and my comment wasn't about startups at
             | all, it was about all private equity and I'm not saying
             | thats a golden ticket either.
             | 
             | Whether inadvertent or deliberate, an unnecessary class
             | system exists which should not.
        
             | mikkel wrote:
             | Raising $100-$1k per person is technically easy enough
             | nowadays with crypto. The hard part is keeping it legal.
        
             | vmception wrote:
             | > Making sure an investor has financial acumen helps
             | founders focus because it is hard enough raising money from
             | angels/VC's in $10k+ amounts - imagine if you only raised
             | $100-$1k per person. Egad! Crowdfunding might be an
             | exception to this - but it is fairly new.
             | 
             | That has zero to do with the existence of accredited
             | investor rules.
             | 
             | In the current reality, many issuers have their own minimum
             | investments such as $25k, $500k, $1mm. This successfully
             | keeps out people that either don't have those sums of money
             | or are encumbered by life expenses, far more than the
             | accredited investor rules do.
             | 
             | An alternate reality without those rules also retains the
             | ability for issuers to deny capital from whoever they want,
             | and by soft-denying capital by setting minimum amounts.
        
               | czbond wrote:
               | I don't see this as some equity issue people are framing
               | it as.
               | 
               | Issuers have the rules of $25k, $500k, etc bc they really
               | don't want to deal with inexperienced investors (doctors,
               | dentists, etc, etc).... who get fearful when they write a
               | check, are inexperienced and so try to micromanage, and
               | worry incessantly about exits and can be short sighted.
               | Angels are great at hiding all of this, until after the
               | deal closes.
               | 
               | It makes sense to heavily filter people like that out -
               | it would be damn terrible as a founder to have to deal
               | with 300 people who all invested "their life savings of
               | $10k". If you haven't been involved in many private
               | deals, you might not believe that. But most deals are
               | small, rosey-eyed-until-a-loss-might-occur "angels".
        
               | vmception wrote:
               | I don't care about what the issuers do and I am
               | completely fine with high buyins to filter people out. I
               | want the government out of it completely, but a special
               | purpose accreditation test is fine as I only have issue
               | with the wealth tests and the tests that require a
               | sponsor. (even the series 65 test requires "good
               | standing" as the article mentioned, which is more than
               | just passing the test recently).
               | 
               | People don't need permission to fail financially, they
               | can walk over to any casino and do that. It is merely
               | happenstance that its two different governments
               | regulating casinos (state) versus these particular
               | capital formation rules (federal). But the user
               | experience for the individual doesn't factor that in, and
               | there shouldn't be a discrepancy at all. The argument in
               | favor of "protecting people that actually need their
               | money by deputizing everyone else" is so thin and weak.
               | As we know, these kinds of "deputize everyone else"
               | regulations only exist because a direct prohibition from
               | the state to the individual would undermine at least one
               | of the individual's constitutional rights.
        
             | gahays68 wrote:
             | It doesn't require financial acumen to follow a lead that
             | has qualified a deal. It is technically possible to form
             | syndicates that corral millions of small checks
             | (Blockchain) to follow leads. And while startups are risky,
             | the investing discipline is simple: spread your bets among
             | several "qualified deals", like poker. Anyone skeptical of
             | this should download Fantasy Startup at Doriot.com which is
             | working to qualify non-millionaires as SEC
             | Accredited....you'll quickly discover that everyone can
             | (and should) be investing in startups. All that needs to
             | happen is, first, education, and second, scaled access.
             | Scaled access will follow once there is a large and growing
             | educated population of Mainstreet investors. The average
             | age of the Accredited investor is close to 60 years
             | old....while 98% of GenZ's and Millennials don't qualify.
             | Does it really make sense to cockblock the generations that
             | should be investing (given they have time and ability to
             | take on risk) and they have to live with the investing
             | decisions of today?
        
               | czbond wrote:
               | Awesome - no reason to keep anyone from investing in
               | them. Anyone loses their money, their fault no matter
               | position in life.
               | 
               | Doriot slots into my "crowdfunding" comment above. Agree
        
               | icedchai wrote:
               | I've invested in several startups, as an employee
               | exercising options, and also as an investor. Unless you
               | have a _lot_ of money to spread around, you 're better
               | off investing in the stock market.
        
               | vmception wrote:
               | I've invested in several private equity funds, and many
               | times those funds negotiate things that are far more
               | lucrative than equity, such as temporary or permanent
               | revenue splits, convertible notes which may be partially
               | paid off before converting into extremely large positions
               | in the companies, you name it. In this structure, I
               | realize from experience, that it is not possible to
               | compare the fund's performance to the stock market, as
               | every limited partner has their own unique exposure to
               | investments that all perform differently.
               | 
               | I've seen the headlines that match what you said, the S&P
               | returns more than picking various startups to invest in
               | most of the time, and that many funds also mirror that,
               | in reality I think all discussion about this is
               | inaccurate, because there are additional variables to
               | account for. Maybe actual equity will underperform just
               | picking S&P equity. But so much more is actually
               | happening which will never show up on a cap table or
               | comparison of valuation growth or any mandated
               | disclosure.
        
             | [deleted]
        
             | ghaff wrote:
             | Someone I know retired from an executive role at a tech
             | company and, in retirement, he got into doing a lot of
             | angel investing. He mostly got out of it except for a few
             | companies he especially believed in. He told me he would
             | have done far better investing the money in a handful of
             | large tech companies.
             | 
             | People think there are these high-return (after adjusting
             | for risk) investment opportunities out there off limits to
             | the plebes. And it's mostly not true. Sure you can get
             | lucky. But over the past decade you could have made a lot
             | of money on boring big company investments.
        
         | slowhand09 wrote:
         | I've been looking at Kinesis Money as a potential investment
         | and hedge. They have a KVT - Kinesis Velocity Token, which
         | cannot be sold to investors in the US, unless they are
         | accredited investors. There are other avenues to obtain one,
         | but apparently they require verification if getting it directly
         | from Kinesis.
        
         | ttul wrote:
         | Well, maybe. But if your net worth is < $2M and you want to
         | build a portfolio of 20 or so startups and then let that play
         | out for a decade until one or two have popped and the rest
         | failed or languished, you are going to need steel balls.
        
           | [deleted]
        
           | vmception wrote:
           | But you can also invest in a fund that gets better deal flow,
           | and your exposure can be more easily spread around.
        
             | cortesoft wrote:
             | You don't need to be an accredited investor to invest in a
             | fund that invests in startups.
        
               | sanderjd wrote:
               | Is this true? Wouldn't it have to be publicly traded?
               | What publicly traded seed / venture funds are there?
        
               | iammisc wrote:
               | The commenter you replied to above is half true.
               | Accredited just means you can invest in securities not
               | registered with the SEC, like your friend's bakery. Some
               | funds are registered with the SEC, some are not. Some
               | funds only accept accredited investors, some do not.
               | 
               | Anyone can sell stock to non-accredited investors... it's
               | just that it costs much more to do so, so most don't.
               | Instead, they go to the already rich upper-class and make
               | them richer when the investments pan out.
               | 
               | One aspect that goes completely unmentioned in all this
               | is the racial aspect. Many people want equality today,
               | but the fact is that for many minorities, they are
               | dependent on an upper class that is mostly white to raise
               | their money. Instead of being able to issue stock
               | directly to members of their own community (and people
               | they likely have closer relationships with), they have to
               | make a case to people they've never met and are not
               | daddy's best friend. If we really want equality, it's
               | time to end these restrictions.
        
               | lovecg wrote:
               | The SEC actually recognizes the issue and is studying
               | possible revisions though no changes have been made yet:
               | https://www.sec.gov/files/review-definition-of-
               | accredited-in...
               | 
               | There are some reasonable sounding ideas they list:
               | 
               | - Permit individuals with a minimum amount of investments
               | to qualify as accredited investors.
               | 
               | - Permit individuals with certain professional
               | credentials to qualify as accredited investors.
               | 
               | - Permit individuals with experience investing in exempt
               | offerings to qualify as accredited investors.
               | 
               | - Permit knowledgeable employees of private funds to
               | qualify as accredited investors for investments in their
               | employer's funds.
               | 
               | - Permit individuals who pass an accredited investor
               | examination to qualify as accredited investors.
        
               | vmception wrote:
               | its good you are aware of their work and on board with
               | the research
               | 
               | you should recognize that's 6 years old and everything
               | that was going to change has already changed, the article
               | of this very thread is about using the new changes
               | 
               | > - Permit individuals who pass an accredited investor
               | examination to qualify as accredited investors.
               | 
               | Only a _further expansion_ this last point is what is on
               | the table. As taking several FINRA tests do now allow for
               | qualification as accredited (as seen in OP 's article),
               | and people get to submit new non-FINRA tests, their
               | approval has not occurred yet.
        
           | anamax wrote:
           | 20 is barely enough. You really want 30-40.
           | 
           | The problem is variance. If 70% fail and only 10% produce
           | meaningful returns, you want >>10 so you have a reasonable
           | chance of getting average returns.
           | 
           | It's possible to get lucky with 5-10 startup investments but
           | the common result is "lost everything" with "broke even" a
           | close second.
           | 
           | This applies to working for startups as well....
        
         | 1cvmask wrote:
         | There are so many examples of investors passing over friends as
         | investments.
         | 
         | In fact from anecdotal observation people do not invest in
         | friends in general. It is people one or two removed who take
         | the plunge.
        
           | cortesoft wrote:
           | This is probably smart. Running a startup is stressful enough
           | without worrying that you are risking your friends and
           | family's life savings.
        
             | sanderjd wrote:
             | On the other hand, this is how Warren Buffett got his
             | start, and (from his biography Snowball) it seems to have
             | been a strong motivator for him.
        
               | cortesoft wrote:
               | Yes, someone wins the lottery. I don't think we should
               | use that as evidence that playing the lottery is a smart
               | financial decision.
        
       | hbcondo714 wrote:
       | For those of you who want more of an introduction to securities,
       | checkout FINRA's Securities Industry Essentials (SIE) Exam. It's
       | only $60 and open to anyone aged 18 or older, including students:
       | 
       | https://www.finra.org/registration-exams-ce/qualification-ex...
        
       | ramraj07 wrote:
       | It's interesting that OP living in a midtown apartment thought a
       | 195 dollar Kaplan subscription is too much money and skimped on
       | it while spending a lot of their time (wasting) on subpar
       | material. Doesn't exactly bode well for good investment acumen
       | does it.
        
         | gregshap wrote:
         | The author said they were in college. In their defense its not
         | uncommon to have loans or parent funding for the expensive
         | apartment, but limited discretionary income and limited ability
         | get money from the 'college' bucket to the discretionary
         | bucket.
        
           | vineyardmike wrote:
           | > limited discretionary income and limited ability get money
           | from the 'college' bucket to the discretionary bucket
           | 
           | He did say he was funding college from a margin loan on his
           | stock portfolio, however.
        
             | gregshap wrote:
             | Ha, didn't read that part. I wanted to attest to the
             | experience of being a low budget student in a high cost-of-
             | living city. The author might not necessarily be that!
        
         | fsckboy wrote:
         | > _living in a midtown apartment_
         | 
         | he said he lived in the east village, took the test in midtown
        
         | diab0lic wrote:
         | They do admit that mistake and adjusted their viewpoint in the
         | article.
        
           | Arcuru wrote:
           | Yes, but only after they pirated it, admitted to doing so in
           | a front page Hacker News article, and then suggested other
           | people do so too.
           | 
           | Do you think tech startups really want an investor who
           | advises people to pirate software?
        
             | JamesBarney wrote:
             | I imagine that consideration is very far down the totem
             | pole of things companies care about their investors.
        
             | fsckboy wrote:
             | to be fair, the Kaplan materials were particularly good at
             | teaching him about the securities laws and compliance
             | section of the exam :)
             | 
             | his stated goal was not to be an investment advisor though,
             | it was to be able to invest himself
        
             | gjs278 wrote:
             | nobody cares about individuals pirating software or
             | subscriptions
        
       | loourr wrote:
       | Prime example of why people should be allowed to do this kind of
       | investing through a retirement account. Doesn't require you to
       | have money, just knowledge.
        
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       (page generated 2021-10-14 23:01 UTC)