[jonnathanson]

"but that argument is something entirely separate from the crowdfunding argument."

True, but I'm actually less worried about the danger to individual retail investors, and more worried about the externalities to the system imposed by a mass influx of speculative crowdfunding -- externalities that can easily wipe out the retail investors, even if their losses aren't concentrated too heavily in any one company.

"The current law basically says that anyone without $1 million and $200k in the bank is too stupid to invest in a startup but someone with that money is smart enough to."

There are two ways to look at the meaning of the current law. The first is that yes, the law views net worth as a proxy for sophistication, and therefore those without high net worth are deemed "too stupid" to invest in private companies. The second interpretation is that those with net worth in excess of $1 million (or whichever benchmark we choose) are capable of absorbing speculative losses, while others are not.

I agree with you that crowd-pooling gets around this issue, and it's interesting in that respect. But I still think it opens the door to too many unintended consequences.