Should You Be Bullish on Seed Stage Investing?

Leave a comment

The Silicon Valley Venture Capitalist Confidence Index, a quarterly survey of top VCs in the Bay Area, released its Q2 findings this week and noted a downtick in overall investor confidence for the second consecutive period, bringing the index to its lowest level in 2 years.

Much of the concern over the state of the early stage market seems to stem from “frothy valuations” and an influx of capital from non-traditional venture investors (think Goldman Sachs and other large financial firms).

Some investors, however, remained upbeat about the state of the private technology market.

Igor M. Sill, Geneva Venture Management

“I sense that continued new IPO activity and cash-rich treasuries at Amazon, Apple, Cisco, eBay, EMC, HP, Microsoft, Oracle,
 Salesforce will yield high valuation acquisitions of venture-backed startups. Shareholders are embracing acquisitions that promise greater market share and growth opportunities.”

Paul Holland, Foundation Capital:

More and more extremely talented young people are forgoing jobs in large companies in favor of starting new businesses at a pace and scale unheard of in the history of the Silicon Valley. The stage is set for the continuation of one of the longest sustained periods of expansion in the Valley’s history.”

The investors in the USF survey above generally represent growth stage firms and invest in late stage deals, which often possesses different characteristics than the seed stage market as different types of investors — institutions and individuals — assess the risk-return equation differently up and down the venture stack and allocate capital differently.

So what does investor sentiment look like at the early stage, where individual investors have the ability to meaningfully participate in rounds for highly promising companies who are in the early stages of finding product-market fit?

The VisibleVC and Hyde Park AngelsInvestor Sentiment Index, which is taken by over 100 VCs and Angels active at the seed stage — showed that respondents are very bullish on the quality of companies at the seed stage, with a “Company Quality Score” of 92 (100 is the best).

“The talk of a bubble in the startup world has been intensifying over the last few years with many people publicly anticipating a major shakeup. The doom and gloom outlook that makes headlines and drives clicks doesn’t seem to be shared by our group of survey respondents, at least in the near term.” — The Sentiment Index from VisibleVC

Despite the fact there may not be enough capital to accommodate all of these companies successfully raising a Series A round (there never is, no matter what market cycle we are in), investible companies with compelling products and strong traction will continue to have access to funding.

So should investors be bullish on investing in the seed stage market? We have identified three key drivers that contribute to an optimistic case for the future Seed Stage market and for investors active at the stage.

The funding cycle has changed significantly

In 2010, YCombinator’s Paul Graham predicted a future where financing at the early stage is continuous, not discrete.

“The future [of funding] is no fixed amount, no fixed closing date, and no lead.”

Many other investors, like Paul Martino of Bullpen Capital have echoed this sentiment as well.

In the years since, fewer and fewer companies have followed the typical VC fundraising trajectory. Well-known companies like Mattermark and Nuzzle have raised second seed rounds in an effort to shorten their fundraising process and buy themselves time to continue strong their strong growth trajectories and raise institutional rounds with terms that work for them.

Writing and talking about the impending Series A crunch may drive clicks for media outlets but displays a fundamental misunderstanding of the way many high growth, early stage companies are raising money in the current environment.

Early stage backers are more capable of investing in follow-on rounds.

Early stage investors — whether funds or individual angels tend to have the most alignment with the vision of a founding team since they are around in the beginning stages of a company’s life. In the past, however, investors who have invested early have often been shut out of later rounds simply because they did not have enough capital to participate. This is changing in a couple different ways and has made it so that investors who get in early on companies can continue to support them over the long term and also maintain significant ownership in the company and reap the full benefits of a successful exit down the road.

1. Since 2011 the median size of institutional seed funds has increased by 66%, meaning that seed funds can now retain more capital to invest in the most successful companies they back early.

2. Alternative funding vehicles — like SPVs through online funding platforms — have emerged, making it possible for groups of individual angels from different geographic to pool capital in order to participate in late stage rounds for successful companies.

Companies are disrupting entire industries…not having to create new ones.

As Paul Holland of Foundation Capital noted in the SVVCCI Survey, technology has invaded every industry and vertical to the point where every company, established and starting up, needs to think of itself as a technology company.

For the first time in the history of Silicon Valley, the largest sources of growth are coming from entrepreneurs *disrupting* existing businesses (transportation, finance, food, media) versus creating new industries like lasers and semiconductors. These existing markets are several orders of magnitude larger than the original markets that formed the basis of growth in the early Silicon Valley.

A quick look at successfully funded SEEDCHANGE-listed companies shows this to be true. For example, the prosthetic limb market is well-established — in Europe and the United States alone there are over 5 million people amputees that require prosthetic limbs. So for UNYQ, a company listed by SEEDCHANGE in 2014, the market already existed, it became a matter of providing a better experience for amputees by leveraging 3-D printing technology to create a better, more fashionable prosthetic limb. This is something that the company has done successfully in recent periods, culminating with the announcement of their multilayer partnership with publicly traded 3D Systems earlier this year.

Making short-term projections for the early stage market as a whole can be a fool’s errand. As some in the survey noted, the Fed could raise rates or other macro concerns could come to pass, causing capital to move away from he market for a period. What does seem to be becoming more clear as time goes on is that a larger share of innovative products and ideas are coming from early stage companies who will end up changing the business landscape regardless of which market cycle they are founded in, providing strong returns for their investors in the process.

Originally published at on August 16, 2015.

The Ostrich Effect in the Banking Industry

Leave a comment

Startups are chipping away at this highest margin pieces of a traditional banking operation. And when you take a look at this graphic from a recent article by The Financial Brand, it is pretty easy to see why this is occurring.

Therein lies one of, if not the biggest problems, with traditional banks today. Few people working in positions of authority (Director to C-Suite) seem to have a holistic understanding of how the industry is evolving and have chosen to bury their collective heads in the sand waiting for the startup danger to pass. It won’t. For just 18% of executives to have an understand of what LendingClub — a public company with a market cap of over $5 billion — does is inexcusable and must be depressing for shareholders of the banks where these executives receive their paycheck (and of course, their bonus).

“The vast majority of the leadership of banks don’t understand exactly how digital works and are very worried about the digital bank. They have a subset of a subset of a subset of their employee base running large percentages of their business without the leadership knowing exactly what’s going on inside.” — Alessandro Hatami, Founder of Pacemakers and former Digital Payments and Innovation Director at Lloyds Bank

Venture investment into FinTech at all stages has been skyrocketing and the growth is expected to continue. Add to that the likelihood that, as evidenced above, innovation is unlikely to occur within the walls of incumbent players and it is clear that what happens in the next few years will have an outsize impact on the future the banking industry.

The race is on to see whether existing banks can fend off their complacency-driven decline by effectively acquiring and/or building meaningful partnerships with upstarts in the industry — rebundling, essentially — before those new entrants gain too much market traction and leave today’s large institutions doing nothing more than grasping onto their existing customer bases with little room to grow and no way to claw back lost business.

De Novo? Don’t Think So

“Tesla created a new car, we’ll create a new bank.” — everyone’s first thought when looking to disrupt banking

According to a late-2014 paper from The Federal Reserve Board, over 2,000 new banks were formed between 1990 to 2008, more than 100 per year. From 2009 to 2013 only 7 new banks were formed, fewer than 2 per year. In the regulatory environment that followed the financial crisis, the FDIC tightened its policy on de novo (new) banks, noting a higher degree of failure for these types of institutions.

A bank starting today would almost surely take after many of the current FinTech startups in the market and offer a customer-centric experience, remain capital-efficient (no brick and mortar banks, more efficient online marketing, etc.) and be more selective in growing its workforce. Stripe, not a bank but an example of a modern FinTech company that has scaled efficiently in the face of high security and regulatory burdens, has been valued at $5 billion and has only 250 employees.

This approach, it seems, would help mitigate some of the risks associated with starting a new bank. Acquiring an existing bank, according to the appendix of Standard Treasury’s recent Series A pitch deck is also likely a no go since regulators have heightened their scrutiny of both non-banks buying banks, especially ones back by venture or private equity investors, who they perceive as having “short term profit motives.”

Additionally, an acquisition would minimize many of the benefits of starting from scratch since the acquirer would need to service existing clients, deal with legacy technologies, and likely manage some physical locations.

Alas, with the regulatory environment remaining relatively unchanged and the costs associated with trying to enter the market unlikely to go down, the path to building a hugely successful company in the financial space will require companies to own specific verticals before branching out (call it “unbundling), into adjacent spaces.

The Personal Finance Stack

The regulatory environment (in the United States, at least) makes is almost certain that the banking landscape won’t be getting it’s own version Tesla — a fully integrated, soup to nuts banking firm — any time soon. So where does that leave the near term future of the banking industry, especially in the United States?

It is already becoming clear that the bank of the future will be of the mobile-first variety. According to research by UBS and KPMG, mobile banking is expected to more than double in the next four years to almost 2 billion people. Add to that the fact that new finance-focused apps run laps around their incumbent counterparts in terms of ease of use and integrations with other applications and it seems that the banking branch as we know it is being downsized to fit in a folder on our iPhone screen.

A la carte banking is nothing new as existing players have been offering it for years as a way to seem more customer-friendly and help people find the right solution to fit their needs. Unfortunately, this still sticks consumers with the same “jack of all trades, master of none” bank that they had before. The new a la carte approach — call it one’s “personal finance stack” — makes it possible for individuals to ensure they are using best in class product for each category.

For early-stage investors looking to capitalize on the unbundling, the trick lies in understanding which pieces of banking will come crumbling off the tower next and the best way to do that is to do the opposite of the head-in-the-sand executives we talked about earlier. Look and learn about what is out there, then try it out. Betterment to replace high-cost advisors (who likely don’t have an app), Digit (who has built an addictive SMS interface), Venmo (to make quick and easy mobile payments). Once you’ve built an understanding of the market landscape as it stands today, you start to gain a clearer picture of where things may be heading and can allocate your capital accordingly.

Originally published at on August 9, 2015.

Why Innovation Fails in the Corporate World

Leave a comment

In the early-stage world, eyes tend to roll when a new corporate accelerator or innovation lab is announced and often for good reason. As research firm CB Insights recently noted in its newsletter, these large corporates are generally more interested in looking innovative than actually innovating.

In recent years, companies like Wells Fargo, Sprint, Volkswagen and General Mills have all launched accelerator programs, in theory to learn from emerging companies and adopt some of the best practices for innovation internally. In reality, innovation efforts at large companies, no matter how well intentioned or how much money they have behind them are often a facade for a few key reasons.


According to this Harvard Business Review article the “median life span of corporate venturing programs has traditionally hovered around one year.” It is the same as when people start exercising just because they want to look better. Their efforts generally fail since there is not an intrinsic desire to bring their vision to reality.

One reason many corporations struggle to find success in building or incubating young companies is a lack of understanding around the time and focus it takes to innovate or to support others who are doing so. More and more accelerators, incubators and innovation centers — both corporate-backed and not — open their doors each month and as this recent TechCrunch piece noted, most fail. Top accelerators are able to attract top talent but the number of slots in that upper echelon is limited and as more accelerators come into the fold, competition is increased.

*via Pitchbook Data

Innovation, whether creating it or supporting it, can’t be a side or vanity project and at many large, established companies, that is exactly what it is.

Risk Tolerance

In the aforementioned CB Insights look at “corporate innovation” one of their eight (facetious) rules for helping big companies become innovative is to have people at those companies talk a lot about “failing fast.” It is easy for a company to talk about adopting a mindset that accepts failure as a form of learning but much more difficult in practice, where executives up and down the chain have been raised to focus on making incremental improvements on a quarter by quarter basis.

Successful investing and operating at the seed stage relies heavily on a tolerance for risk. The risk profile of people starting or joining startups is significantly different than the people a corporation has on its own bench to tap when they want to start an accelerator or begin a startup-like initiative. That is not to say there is a lack of talent at large corporations. First Round Capital recently took a 10 year retrospective look at their portfolio performance and noted that founding teams with experience at Amazon, Apple, Facebook, Google, Microsoft or Twitter outperformed peers by 160%.

This is great news for early-stage investors who have the opportunity to invest directly in people leaving the corporate world for the startup world. Corporate work gives potential entrepreneurs the the background and skills they need to identify problems and come up with winning solutions but not the culture to support the building of those solutions.


At early-stage companies, urgency (often bordering on the side of panic) is the name of the game. Everything is a race against the cash clock as teams try to build product, acquire customers and attract investors before their position becomes too desperate. And it isn’t just the company’s livelihood that hangs in the balance when people commit to building a startup from scratch.

In his post titled, Entrepreneurshit, Upfront’s Mark Suster noted that “as a startup founder you rarely have much money in your bank accounts. Neither in the personal nor business account. That’s stressful enough.” As an example, he pointed to a young founder that claimed he hadn’t had more than $8,000 to his name since starting his company.

This degree of urgency — and the level of commitment and risk tolerance it takes to get to that point — breeds many things, chief among them a desire to push forward and build something truly outstanding that will make the sacrifice and the emotional toll worthwhile.

As hard as they may try and as authentically as they may want it to be so, large companies descending on the early-stage market will never be able to fully replicate the levels of commitment, risk tolerance and urgency it takes to build truly innovative products and businesses in a market as competitive as it is today.

Originally published at on August 1, 2015.

Uber and the Benefit of Building Social Capital

Leave a comment

Since hitting what was then reported to be a $330mm valuation in 2011, just two years after launching, everything has seemed “up and to the right” for Uber. Its valuation rose to $3.5b by 2013 then $17b in 2014. In the last 7 months or so, the ascent has continued, reaching what is now believed to be around $50b. For perspective, that makes Uber — again, a company that launched in 2009 — larger than 80% of the S&P 500.

This valuation, it has been assumed, has been earned on the back of an extremely lucrative business model that will only get more lucrative as it matures in many of the markets it is operating in. A recent Bloomberg report, which revealed smaller revenue numbers and higher operating losses for the company than most in the market assumed, makes this outcome seem like less of a foregone conclusion than had been expected. The leaked numbers don’t paint a perfect picture of Uber’s financial and operating positions since we do not know exactly which period the numbers correspond to but are instructive in that they show how difficult it will be for Uber to justify the mega valuation it has reached.

As a business, it is highly doubtful that Uber will fail to be a going concern any time soon. The end game for recent investors, who dumped huge amounts of capital at an overheated valuation into the company, is less clear. Losses in venture backed companies are not abnormal and are generally endorsed by investors pushing the company to grow. However, when taken in context with other recent news surrounding the company, the competitive landscape, and the markets they operate in, the financial numbers begin to paint a less than ideal picture of a company that everyone — from top-tier VC firms to massive asset managers — has been falling all over themselves to invest in.

Over the last couple of weeks, top Uber executives in France were arrested and UberPop (Europe’s version of UberX) was shut down in the country, something that had long been expected in the face of violent protest from the taxi industry and complaints about unethical business and employment practices. This comes on the heels of a (non-binding) ruling by the California Labor Commission that said an Uber driver should be classified as a W-2 employee instead of as an independent contractor. If changes are eventually made to the way on-demand workers are classified, Uber (and its domestic rivals) face higher costs and increased labor-related scrutiny.

Perhaps most worrisome for some later Uber investors is the way that the competitive landscape has developed around Uber in recent periods. One often invoked statistic is that investors are valuing Uber as if it is bigger than the world’s entire taxi market. This criticism neglects to acknowledge the fact that Uber’s ambitions are much larger than being simply a massive taxi company. With their goals of replacing car-ownership and their efforts to develop mapping and self-driving technology and branch into on-demand delivery, this is obvious. What the valuation does seem to indicate is that investors believe the worldwide market for Uber’s services is a winner take all one, with the expectation obviously being that it will be Uber standing alone when the dust settles.

As Stretechery’s Ben Thompson wrote in late 2014, the markets that Uber is competing in are transactional in nature, meaning that lower prices will be the key to winning them. In this scenario, Uber enters a market and can bleed competitors dry through higher spending, which builds upon itself by improving marketplace liquidity and allowing them to offer lower pickup and delivery times.

While the on-demand market still possesses the above characteristics, it is looking more and more like individual, regional markets may be winner take all, but the global market may not be for a few important reasons.

Protectionist governments and consumers, or the benefit of building social capital

Katherine Teh-White of global consultancy, Futureye, has been quoted many times in Uber-related articles for her thoughts on the “social license” companies need to operate, especially in new markets.

New businesses actually have to establish a social license to operate. This is the agreement by society or a community that an organization’s practices and products are acceptable and aligned with society’s values. If society begins to feel that an industry or company’s actions are no longer acceptable, then it can withdraw its agreement, demand new and costly dimensions, or simply ‘cancel’ the licence. And that’s basically what you’re seeing in Europe and other parts of the world with Uber.

Uber’s battles across the globe are often painted as Silicon Valley tech company vs. old world, anti-innovation governments and while to a certain extent this may be the case, it certainly doesn’t tell the entire story. For example, Uber drivers have faced stiff fines in many European cities, something that Uber the company has repeatedly picked up the tab for. This contempt for local laws, as onerous as Uber may find them to be, raises concerns of citizens as well. If Uber fails to comply with these rules, as Bloomberg’s Leonid Bershidsky, where does it stop? What other laws and regulations, possibly around workers right, will Uber choose to ignore.

Well-funded niche (and not so niche) competitors

United States based consumers, especially ones near major markets, are familiar with Lyft, the benevolent underdog who operates in about 65 cities in the United States. Lyft is well funded to the tune of about $1b and has proven to be a viable, if not overly threatening, antagonist in the Uber story. As touched on above, however, Uber’s ambitions are larger than simply being a taxi company, which means they are competing with a host of other well funded (less well funded, of course, than Uber itself) companies aiming to stake claim to sizable chunks of the on-demand economy before Uber has time to get around to the space.

In the same way that Uber and Lyft have been fighting an intense turf war in the United States, Kuaidi and Didi were battling it out for supremacy in China. That is, until they merged earlier this year, creating a combined company that now owns almost the entirety of the Chinese market and will make it difficult for Uber to gain any significant foot hold.

Again, on a regional basis, the market for ridesharing and other on demand businesses that Uber would like to branch into seems to be winner take all in nature and if Uber can’t deliver the same level of liquidity as its competitors in these areas, it stands little chance.

Other competitors like Singapore’s GrabTaxi and Ola, which operates in India, pose the same threat in other Asian cities. According to CBInsights, these three SoftBank-backed companies (including Didi Kuadi) have now raised more capital in total than Uber.

While Uber may be pulling further and further ahead in the U.S., it will need to grow rapidly in major emerging markets in order to justify investor expectations, something that seems unlikely to happen in light of this increased competition and the company’s inability (or disinterest) in building the social capital required to operate effectively in these new locations.

Originally published at on July 24, 2015.

Investing in Enterprise SaaS

Leave a comment

Investors love businesses where the revenue and growth models are easily predictable. One of the best examples of this is in Enterprise SaaS, where customers essentially outsource the running of its software to the vendor. Additional software updates are made quickly and painlessly without time consuming and expensive on-site implementation. This ease of use tends to lead to customers sticking around for a long time.

As those customers stick around, the revenue continues to pour in without any additional sales and marketing costs for the company. All of the costs of customer acquisition were incurred upfront and many periods prior.

The SaaS growth curve: Costs (and negative cash flow) upfront, high margins later as sales and marketing spend no longer spent on “reacquiring” customer (via @a16z)

One of most the most alluring features of indexing heavily towards enterprise software it that it is essentially a bet on a proven and growing business model (Software as a Service) instead of one on a particular industry segment or vertical. Deal room software, for example, is used by large corporations of all stripes — from technology giants like Google to financial firms like JPMorganChase.

Startups focused on corporate users are benefiting also as employees adopt personal smartphones and tablets for work. This has triggered increased investment by companies in new tools to manage mobile and cloud-based computing. Web services for purchasing, security, back-office infrastructure, customer support, human resources, payroll, and salespeople have become popular within the private sector.

This “usefulness” and their clear path to revenue has buoyed both investment dollars and exits values for enterprise SaaS companies. In 2013, 70% of the 50 largest VC financing rounds were in enterprise software companies. And it is not just dollars going in. In that same year, 84% of the 50 largest U.S. VC-backed exits were enterprise software companies.

Originally published at on July 3, 2015.

The FinTech Boom

Leave a comment

“Silicon Valley is Coming”

The Financial Services space has long been one of the most complex industries to operate in, as regulation and security concerns have insulated traditional incumbents from disruption and protected many high margin lines of business. Now, with technology enabling new entrants by helping them build — both products and customer bases — more quickly and securely, the traditional market participants are being attacked from all angles as specialist startups look to beat big banks and other longstanding institutions in their most profitable areas. In other words, as CB Insights has put it, FinTech startups are in the process of unbundling what we traditionally know to be a bank.

In March, Goldman Sachs — themselves a large player in the venture market as an investor in both FinTech and non FinTech startups — estimated that $4.7 trillion (yes, with a ’T’) in revenue for traditional financial services are at risk of being displaced by new tech-enabled competitors. That huge opportunity helps explain the boom in FinTech venture capital investment in recent periods. A report from Accenture earlier this year noted that global FinTech investment has tripled since 2008 to nearly $3 billion…and the growth isn’t slowing down. New technologies, shifting customer behavior and regulatory changes mean that the market could reach $8 billion by 2018.

Based on the the way things currently operate in the financial sector, bulge bracket banks and huge asset managers need all the help they can get. It’s a little-known but terrifying secret that all the big banks still manage their financial activity with manually created Excel spreadsheets that employees email and fax around the world every day. Without 1980s technology, operated by hand, the financial system as we know it would stop operating!

The word disruption is overused in the startup world, but the work that many new entrants are doing — building cloud-based infrastructure that is faster, more secure, and more efficient that last century tools, for example — is playing a large role in upending one of the largest industries in the world.

“First generation online financial services companies … traditional banks, asset managers, and payments companies are all working to adapt to these behavioral, demographic, and technologic realities,” the report said. “We expect partnerships, acquisitions, and competition will be key to the way the vertical develops.” — Goldman Sachs Report

To their credit, the traditional players have taken notice, competing with and investing in some of the top companies encroaching on their lucrative territory. Many — like Citi and BBVA along with GS — have launched investment arms, adding to the massive wave of FinTech funding and creating what could become a very active M&A market for venture backed FinTech companies.

As Jamie Dimon recently told shareholders, “Silicon Valley is coming. “There are hundreds of startups with a lot of brains and money working on various alternatives to traditional banking.

He is certainly correct as there are hundreds (actually, thousands) of companies are working feverishly to bring Financial Services into the 20th century. FinTech companies and the innovation they bring aren’t just coming, however, they’re already here. And they’re here to stay.

If you are an accredited investor, SEEDCHANGE offers you the ability to analyze and invest in high growth Fintech companies all on one easy to navigate online platform.

This post was featured in the May 31, 2015 edition of the SEEDCHANGE Digest. To subscribe to receive similar insights, along with the weeks top tools and links for early stage investors, you can subscribe here.

Originally published at on May 30, 2015.

The Voting Machine vs. The Weighing Machine

Leave a comment

If a VC blog post doesn’t include the term “Unicorn” does it actually exist? Much of the week’s column space (in the early stage world, at least) cautiously celebrated massive growth funding announcements and debated the dynamics of the VC <> entrepreneur relationship in light of the Secret shutdown.

Money continues to pour into growth rounds but the takeaway isn’t clear and likely won’t be for some time. In the cases of Zenefits, Slack, and others, we have companies with impressive growth going after massive addressable markets while raising what some think is too much money at unsustainable valuations that places an onerous amount of pressure on the companies to maintain their rapid growth trajectories.

To paraphrase Benjamin Graham, the popularity contest comprised of TechCrunch clippings and VC dollars chasing the next hot deal (the short term voting machine) will eventually give way to the long term market weighing machine where the underlying performance of the companies in questions will matter more than the often fickle opinions of people on Sand Hill Road.

What We Learned This Week

1. Valuation is — and probably shouldn’t be — becoming the “entrepreneur’s scorecard”

USV’s Fred Wilson advises founders, and the people investing in them, to fight against the market’s influence to use a number to measure the entire worth of the company. Things like whether employees and customers are happy, whether you the business you are building is becoming sustainable, and whether the brand you are building is gaining respect are much more important in the long term.

2. Companies and investors looking for perfect seed rounds should focus on simplicity.

A great lead investor surrounded by value added angels who invest in a round at a reasonable valuation (while keeping the terms as vanilla as possible) is what it takes to make the perfect seed round.

3. Focus on building “forever companies”, not “Unicorns”

Andrew Chen looks to Amazon’s Jeff Bezos as an example of someone building a high growth, scalable forever company and advises founders and investors that these types of organizations don’t have to be “lifestyle businesses”.

4. Companies seem to be specifically negotiating for $1 billion valuations

Law firm Fenwick & West dug into the deal terms for 37 recent U.S.-based venture backed companies recently valued at over $1 billion. Prevalence of dual class voting structures and downside protection for investors are just a couple of the key takeaways from the report.

Originally published at on May 14, 2015.