What is the North American Securities Administrators Association (NASAA) likely position on Regulated Investment Crowdfunding?

This is the article that reported on NASAA and that prompted the question: https://www.investmentexecutive.com/news/from-the-regulators/nasaa-defends-public-markets-investors/
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Based on the report by the North American Securities Administrators Association (NASAA), it seems likely that they would have a cautious stance toward Regulation Crowdfunding. The report emphasizes the importance of defending public capital markets and raising concerns about efforts that expand the incentives for staying private. This suggests that NASAA may view Regulation Crowdfunding as a potential threat to public markets and the traditional principles of securities regulation.

The report expresses concerns that legislative proposals, such as those in the JOBS Act 4.0, could erode public markets and adversely affect businesses and investors that rely on those markets to raise investment capital. NASAA also highlights opposition to proposals that would limit the role of state regulators in overseeing capital raising in the private market. This stance suggests that NASAA is likely to be cautious about expanding exemptions for private offerings and other regulatory changes that could make it easier for companies to raise capital without going through public markets.

However, NASAA does support certain proposals that could enhance investor protection and improve coordination among state and federal regulators. For example, they advocate for a comprehensive enforcement database that covers everyone convicted or held liable in criminal, civil, and regulatory actions involving financial services. They also call for stronger coordination between state and federal regulators and improved regulatory data collection, particularly on activity in the private markets.

Overall, while NASAA is likely to be cautious about Regulation Crowdfunding, they are also interested in finding ways to improve investor protection and strengthen regulatory oversight in both public and private markets.