Can you do crowdfunding with Regulation A?

Everybody’s buzzing about the fact that on Wednesday the SEC is going to adopt changes to Regulation A, finalizing the changes to Reg A that were mandated by the JOBS Act and first proposed by the SEC in December 2013.
Assuming that the SEC makes the right call on state preemption (ie, votes to have Regulation A+ offerings reviewed only by the SEC and not by the states), this will make it possible for start-up companies to make offerings of securities publicly to all sorts of investors, with offering sizes up to $50 million.
Is this crowdfunding? Yes and no.
Why Reg A+ offerings look like crowdfunding:
You can sell securities over the internet
To lots of people (accredited or not)
In small amounts
Why Reg A+ offerings are less like crowdfunding:
More complex (and therefore expensive) disclosure requirements that are subject to SEC review
You can’t do this without a lawyer
Potentially more limited use of social media – in the earlier part of an offering you can “test the waters” by telling people you are planning an offering; but the mandated language for this won’t fit on Twitter; use of social media will hopefully be clarified in the final rules
No “crowd” – not only is there nothing in the rules mandating the sharing of information with and among the crowd of potential investors, but there are legal and logistical problems involved if you try to create a crowd commentary function
So is Regulation A truly crowdfunding? Well there’s no official definition of crowdfunding and we don’t pretend to be experts in taxonomy, but if the SEC preempts state review we can say for sure it will be a useful capital-raising option for early-stage companies.