Ryan Colucci's Blog, page 10

August 23, 2013

R.E.M. (graphic novel) First 3 Pages

I’m playing a bit of catch up from all of the other social media.  I posted Page 003 today, so that means I need to share the first 3 pages with all of you.



 


Page 001


REM-Page 001


 


Page 002


REM-Page 002


Page 003


REM-Page 003



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Published on August 23, 2013 11:34

R.E.M. – the Kickstarter

Hey all… for the last few months I have been preparing my graphic novel for printing.  Part of that was planning for a Kickstarter campaign for the book.  It wasn’t as simple as throwing the project up there and hoping for the best.  Either way, two days ago the campaign was launched.  You can see it here.


A big piece of the campaign was the trailer for the book.  Zsombor and I put a tremendous amount of effort into it, and the music was done by Dirty South.  How that came about is a long story – but basically I wound up putting together a music video with him and we are working on a feature film… and he saw it and dug it and absolutely killed it. You can see the trailer on the Kickstarter page (after a short intro by me – being very stiff).


REM_cover_KS


We generated over $1,000 on the first day and about the same amount on the second day. As of this post, we are sitting at $2,446 (our goal is $7,000).  The money is to actually print the book and you can learn the more detailed description of everything at the Kickstarter page.


During the course of the campaign I will be releasing a page a day for the 30 days.  It was our goal to give away the first 30 for free and it just happened to work out with the timing of our campaign.  I will also be posting a step-by-step process of each page, which shows the layout/pencils, inked page and then the lettered page.  For the more complex pages I will do a detailed post.  There will be a ton of sleep articles and thing relating to sleep posted as well.  I have a breakdown of each character in a ‘meet the characters of R.E.M.’ segment ready to go.  I will also be sharing quotes on reading from a variety of authors – but twisted a bit to focus on our campaign.


If you have already pledged, I can’t thank you enough.  If not, please give us a look.  I know money is tight – so even if you like what you see but can’t pledge then please share it with anyone you think it might appeal to.  Thanks!



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Published on August 23, 2013 09:42

July 15, 2013

JOBS Act

A few months ago, a great article on the JOBS Act was posted on Ted Hope’s Truly Free Film blog and written by Michael R. Barnard.


Currently, the promise of the JOBS Act is in limbo even after being signed into law over a year ago (and supported by the most bi-partisanship effort in recent history) because the Federal Securities and Exchange Commission (SEC) has failed to enact it.


The JOBS Act established a deadline of Wednesday, July 4, 2012, for the SEC to promulgate rules and regulations for the implementation of TITLE II—ACCESS TO CAPITAL FOR JOB CREATORS (commonly referred to as the “general solicitation rule“). The SEC missed that deadline. The agency did publish proposed rules for TITLE II on August 29, 2012, but has not implemented them. There is no anticipated date for finalizing the rules for Title II of the JOBS Act.


The JOBS Act established a deadline of Monday, December 31, 2012 for the SEC to promulgate rules and regulations for the implementation of TITLE III—CROWDFUND (commonly referred to as “Equity Crowdfunding“). The SEC missed the deadline, and has no anticipated date for the rulemaking to implement TITLE III.


FILMMAKERS, IT’S 2013. DO YOU KNOW WHERE YOUR JOBS ACT IS?


The Internet enlarged the playing field for securities offerings, whether valid or not, and for potential investors, whether knowledgeable or not.


How do you legally and ethically access that hoarded cash and encourage its investment in your well-developed movie project so you can hire people and make your movie?


Easier access to that cash is the promise of the JOBS Act, which was the biggest bi-partisan effort of the past several years of hyper-partisanship. Support for the JOBS Act spanned both parties.


America needs good jobs, and some of those jobs need to come from the independent film industry. Joblessness and low-wage jobs have crippled the survival and prosperity of millions of Americans, and are a drag on our entire economy.


For you, the significance of the JOBS Act is not only the production of your movie, but also its potential to rebuild the infrastructure of the American independent film industry by structuring movie projects to show business as well as artistic realities.


The ability to reach out to investors means you will have to analyze the strengths and weaknesses of your movie project, plan its production and distribution, and calculate reasonable possible returns. Your stronger, compelling plans and successful investor strategy will allow you to pay better wages, attract superior cast and crew, rent and purchase proper equipment, engage legal counsel and insurance, and make stronger efforts to engage audiences and deliver your movie to them. By opening access to that hoarded cash and other cash from investors, the JOBS Act can provide filmmakers with increased production quality and increased likelihood of a return on investment, which can increase the stability of the independent film industry in America. The process can increase the potential to deliver higher-quality movies to larger audiences.


There are two parts of the JOBS Act specifically attractive to independent filmmakers. They are Title II—ACCESS TO CAPITAL FOR JOB CREATORS, commonly referred to as “the General Solicitation Rule,” and Title III—CROWDFUND. These offer the promise to improve filmmakers’ ability to raise money for development, production, marketing, and distribution of their movies.


Some filmmakers are lucky enough to raise money for their movies through family and friends, angel investors, venture capitalists, or other ways of private funding. Most filmmakers are not so fortunate.


Many filmmakers turn to crowdfunding, whether perks-based donor crowdfunding or the forthcoming Equity Crowdfunding. That’s a good path for filmmakers whose social circle is pretty normal, and you will benefit from Title III—CROWDFUND of the JOBS Act.


Are you fortunate enough to have millionaires in your social circle? The change to the fundraising process, opening it up for general solicitation, will be the benefit for you from TITLE II—ACCESS TO CAPITAL FOR JOB CREATORS of the JOBS Act.


TITLE II—ACCESS TO CAPITAL FOR JOB CREATORS


TITLE II is popularly referred to as the “General Solicitation” rule. It will change some of the exemptions from the most strenuous rules; these exemptions, which are still very strict, are commonly referred to by investment professionals as “Sec. 506, Reg. D”. The rules that allow exemptions from some of the harshest regulations still include prohibitions against you, or any person acting on your behalf, offering or selling securities through any form of “general solicitation or general advertising.”


Most of those posts long ago on Friendster and MySpace and those ads printed in magazines and newspapers by filmmakers telling people to invest in their films and promising the investors profits have always been illegal. Examples of general solicitation include advertisements published in newspapers and magazines, communications broadcast over television and radio, and seminars whose attendees have been invited by general solicitation, as well as other uses of publicly available media, such as unrestricted websites and social media.


The big news is that TITLE II is going to let you promote your movie project to everybody you can reach. The only restrictions will be, simply, that you can only sell your securities to Accredited Investors – but you can now find those Accredited Investors by publicly announcing your movie project.
The JOBS Act instructs the SEC to make rules to stop the prohibition against general solicitation and to give you reasonable steps to verify that those who invest in your movie are truly Accredited Investors as defined by law.


You will not be able accept investment money from anyone who can’t prove they are Accredited Investors. The Act says you will not be subject to requirements to be a registered broker or dealer because of maintaining and advertising online or on other platforms your offer, sale, or negotiation of an investment in your movie. Under the general solicitation rules for your Sec. 506 of Reg. D offering, there might be no other reporting requirements other than, probably, the basic Form D now required by such offerings. It is likely the SEC will modify the Form D only to acknowledge that your offering is being made under TITLE II of the JOBS Act.


The JOBS Act established a deadline of Wednesday, July 4, 2012, for the SEC to promulgate rules and regulations for the implementation of TITLE II—ACCESS TO CAPITAL FOR JOB CREATORS. The SEC missed that deadline. The agency did publish proposed rules for TITLE II on August 29, 2012, but has not implemented them. Although the SEC has missed the deadline required by the Act, and used a process a little bit out of the ordinary regarding its usual schedule of receiving public comments and publishing proposals, the SEC believes they are working prudently within the complex requirements of implementing the JOBS Act. There is not yet an anticipated date for finalizing the rules for Title II of the JOBS Act. It continues to accept public comments regarding TITLE II.


TITLE III—CROWDFUND


Title III—CROWDFUND of the JOBS Act, twisted into an acronym of that tortured construct, “Capital Raising Online While Deterring Fraud and Unethical Non-Disclosure,” relieves filmmakers of many of the burdens of raising equity investment for movie projects. The goals of the Act appear to allow a filmmaker (or any entrepreneur) to offer securities to any American for up to a maximum of $1 million in any 12-month period for all of the entities controlled by the filmmaker using the process similar to perks-based donor crowdfunding


It appears the filmmaker’s offering of securities must be made only through a registered securities broker or through a newly-described “Funding Portal” registered with the SEC. Funding Portals are intermediaries that might be similar to the existing crowdfunding sites, and will be responsible for educating the public about investing, protecting the public from fraud, vetting the people offering the securities, distributing to the SEC and potential investors any information about the securities, and holding in escrow all proceeds prior to reaching the offering amount. Funding Portals will also protect the privacy of investors and cannot purchase from any finders or brokers any personal information about potential investors. Filmmakers will not be allowed to be officers, partners, or directors in the Funding Portal servicing their projects.


In order to offer equity shares in their project, it appears filmmakers will need to provide some form of a Business Plan and Financial Projection, which was common before the collapse of the independent film industry, that includes the purpose for the offering and the target offering amount and its deadline, as well as the description of the ownership and capital structure of the issuer. The Business Plan and Financial Projection will likely include the name, legal status, physical address, and website address of the issuer; the names of the directors and officers and anyone with more than 20 percent of the shares of the issuer. A description of the financial condition of the issuer including all other offerings of the issuer within the preceding 12-month period is also required. The filmmaker will need to make regular updates about progress meeting the target offering amount. There will be rules about describing the price, value, terms and class of the securities offered. Annual reports will be required.


WHO CAN INVEST, AND HOW MUCH?


Once the new SEC regulations are in place, you likely will be allowed to approach anyone via any method of communication, describing your well-developed movie project, as long as you only send them to the Funding Portal or broker handling your movie project. If you pay someone to bring people to your project at your broker or Funding Portal, you will be required to declare publicly that you pay the person to do so.


It appears there will be no limit to the Americans you can approach, but their participation will have limits. Expect that those potential investors whose annual income or net worth is less than $100,000 will be allowed to invest up to 5 percent of their annual income or net worth, capped at a maximum of $2,000. Anyone with an annual income or net worth of more than $100,000 will be allowed to invest up to 10 percent of their annual income or net worth, capped at a maximum of $100,000. These maximums will apply to all of the investments made by the individual to all issuers – not just you – in any 12-month period.


It is attractive to filmmakers to be able to raise up to $1 million per year in equity investment. This fits into a common timetable for making movies; the first year’s fundraising could support development, production, and post-production, and the second year’s fundraising could support marketing and distribution, effectively allowing filmmakers to raise up to $2 million for your movie.


The investment securities in your movie will be barely, if at all, liquid. Your investors will likely not be allowed to resell their securities for a period of 12 months except to people such as accredited investors and family members, or through a complex registered public offering in the unlikely case that you were to develop one.


The issue of Funding Portals has become very complex. It originally appeared that the JOBS Act would allow a proliferation of new businesses to serve as Funding Portals. However, complex and contradictory parts of the Act now appear to make it illegal for Funding Portals to earn a profit unless they are functions of registered Broker-Dealers. The possibility of non-profit organizations setting up Funding Portals has not yet been addressed by the SEC. The process of becoming a registered Broker-Dealer could take probably more than six months and cost probably more than $25,000. For the SEC’s information about the process, see here.


“You’re dealing with other people’s money, there is an obligation of financial and fiduciary duty to the investors,” says Bob Thibodeau of Crowdfund Capital Markets, a service company providing backend and clearinghouse functions for equity crowdfunding operations.


“Orderly, transparent, liquid markets are good for everybody,” continues Thibodeau. “The processes, the technology, the understanding of regulatory environments is much more conducive to orderly markets than everybody learning something all at once, which is chaos, which is where crowdfunding is right now.”


The SEC is working with The Financial Industry Regulatory Authority (FINRA), the largest independent regulator for all securities firms doing business in the United States, on rules for funding portals, and FINRA has a voluntary Interim Form for prospective Funding Portals. Once the SEC and FINRA have adopted funding portal rules, they then need to promulgate the rules that will apply to those who need to use Equity Crowdfunding to fund their businesses.


“Investors soon can expect to be inundated with crowdfunding pitches, legitimate or otherwise,” said Heath Abshure, President of North American Securities Administrators Association (NASAA), the oldest international organization devoted to investor protection.


An analysis of Internet domain names found nearly 8,800 domains with “crowdfunding” in their name at the end of the year, up from less than 900 at the beginning of the year.


Fraud concerns run high in certain circles of the professional investment community. However, the openness and transparency of the Internet, according to crowdfunding experts, serves to thwart fraud.


Slava Rubin of popular perks-based donor crowdfunding site Indiegogo, and very active in the process of crafting the Equity Crowdfunding part of the JOBS ACT, says “Indiegogo’s 5,000 campaigns are proven case studies to predict that there is no significant worry about fraud. The fraud rate in our case studies has been about 1 percent.” He notes that when e-commerce was new on the Internet, people also predicted huge increases in fraud. However, eBay and Amazon proved that online fraud risk is no greater than every other risk we face every day.


According to the report How the Crowd Detects Fraud, “This is the new crowdsourced diligence paradigm.” The crowd itself effectively polices against fraud.


PERKS-BASED DONOR CROWDFUNDING AND EQUITY CROWDFUNDING WILL CO-EXIST. 


Perks-based donor crowdfunding and Equity Crowdfunding each has its own process and participants. It is likely perks-based donor crowdfunding will be more focused on funding for personal, artistic movies, while Equity Crowdfunding will be focused on movies with commercial appeal.


Kickstarter is not going to get involved in Equity Crowdfunding because its mission was never profit-oriented over artist-oriented. It launched in 2009 after an original idea in 2001 to fund creative projects that would probably not be profitable, but that were good ideas that people want to see come to life.
For instance, last year Charlie Kaufman, Dan Harmon, Ira Sachs, David Fincher, Bret Easton Ellis and Paul Schrader all turned to Kickstarter to invite fans to participate in their personal creations.


Equity Crowdfunding will be a different experience, and for different backers, than perks-based donor crowdfunding.


The JOBS Act established a deadline of Monday, December 31, 2012 for the SEC to promulgate rules and regulations for the implementation of TITLE III—CROWDFUND. The SEC missed the deadline, and has no anticipated date for the rulemaking to implement TITLE III. The SEC has not published any proposed rules for TITLE III and continues to accept public comments regarding TITLE III.


When the SEC is engaged in rulemaking, they typically want to hear from the public and will say very little beyond what is proposed.


Part of the reason for delays in rulemaking may be the change in leadership at the SEC. On December 14, 2012, Chairman Mary Schapiro left the agency, and President Obama appointed Elisse Walter as her successor. See here and here.


Although the SEC has made few announcements about the JOBS Act and its rulemaking, former Chairman Schapiro spoke about it in her opening remarks at the SEC Open Meeting on August 29,2012 (see here) and current Chairman Walter gave her “Opening Remarks Regarding the Proposal of Rules Eliminating the Prohibition against General Solicitation and General Advertising in Rule 506 and Rule 144A Offerings” at that same meeting (see here)


When it wends its way through the SEC rulemaking processes, the JOBS Act will be a powerful tool that will give filmmakers something they have desired for decades: easier access to investors for their movies.


You face the opportunity to have a significant impact on the future of America’s independent film industry.


You can immediately participate in the process to make sure the JOBS Act supports the needs of America’s independent film industry. The SEC wants to hear from you


As a filmmaker, you can tell the SEC that it’s important to you to be able to have access to investment capital in order to make your movies and to rebuild the independent film industry.


Michael R. Barnard is a writer and filmmaker who has been researching the American JOBS Act since it was first proposed. Barnard is currently working on creating an independent feature film, A FATHER AND SON. Barnard lives in Brooklyn, New York, and is the author of the historical novel NATE AND KELLY. You can reach Barnard on Twitter at @mrbarnard1.


Note: This article is an overview and observation, not legal advice.



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Published on July 15, 2013 14:05

June 12, 2013

FIL Vote Paves Way for Iroquois to Rejoin Blue Division

In a matter I’m sure you all care so deeply about, the last few months – or years – have seen tempers run hot in the lacrosse community.  At the last world games, the Iroquois Nation was denied entry into England due to their native visas (they are issued US visas as well, but do not use them).  That meant one of the top 3 national teams and the creators of the sport were denied a chance to play in the pinnacle of the sport.  This was a black eye on lacrosse and the United Kingdom (in my opinion).


There was a bylaw that existed which stated that seeding and groupings were determined by the finish in the previous world games.  That meant the Iroquois team would be in last place and re-grouped to a different division.  This isn’t like the world cup, where group winners advance.  Lacrosse is broken down into groups because, to be quite honest, most of the teams aren’t very good.  The US and Canada have dominated the sport since the inception – with the Iroquois team being the only other team capable of running with (and beating) either team.  In fact, the last team they fielded was extremely deep – and this team will be even deeper.


The FIL was standing by their bylaw – until a full-on assault came from the lacrosse community to overturn this decision and put them back where they belong. Because this was not about seeding and trophies.  This is much deeper than that.  This is about honoring the roots of the game. For those of us who play, lacrosse is more than a game. It sounds trite, but it becomes your life.  A culture unto itself.


So… that said, FIL held a postal vote and responses were tallied and I’m happy (relieved) to say that they have voted almost unanimously (1 lone jackass held out) to get rid of the bylaw.


I love this game and everything it has given me.  I’m proud to say I’ve played.  Even more so now…


 


 



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Published on June 12, 2013 13:10

June 7, 2013

Where I’ve Been

On the fourth day of June of 1763, the garrison at Fort Michilimackinac, unconscious of their impending fate, thoughtlessly lolled at the foot of the palisade and whiled away the day in watching the swaying fortunes of a game of ball which was being played by some Indians in front of the stockade. Alexander Henry, who was on the spot at the time, says that the game played by these Indians was “Baggatiway, called by the Canadians le jeu de la Crosse.”


The favorite game of ball of the North American Indians, known today, as it was deemed in 1636, by the name of “lacrosse,” was potent among them as a remedial exercise or superstitious rite to cure diseases and avert disaster; that it formed part of stately ceremonials which were intended to entertain and amuse distinguished guests; and that it was made use of as a stratagem of war, by means of which to lull the suspicions of the enemy and to gain access to their forts.


 And that’s where I was for the last few months.  Medicating myself with the game of lacrosse.  Lulling my enemies to sleep with the game I love.  Averting disaster.

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Published on June 07, 2013 13:58

April 2, 2013

USC Sadness

I lost a special person who is directly responsible for where I am in my life/career. Kathy Fogg was one of two people who ran the Peter Stark Producing Program at USC (Larry Turman is the ‘leader’ of the program – but Kathy did all the day-to-day).  I know for a fact she was the one who pulled my application and was the champion for me, which resulted in my acceptance into the program.  And when I received the call I got in and needed to be there within 48 hours, Kathy opened up her home to me.  She put me up in her house for almost a month. I got off the plane not knowing a person in LA, never having been west of Colorado, with no place to live and no car. She (and her late husband) didn’t just allow me to stay at their house, they made me feel like I was part of their family.  Since then Kathy and I always joked that she was my LA mom.  In fact, she had a ton of furniture in storage and gave me most of it. That’s the type of person she was.


I don’t know if I have ever met someone who was more caring, upbeat and giving. It was such a contrast to what you’re told LA is all about, which made the program feel like a family. I think that element will forever be gone no matter how great those who running it are.  And I will forever be grateful to her for so many things.


Rest in Peace Kathy.



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Published on April 02, 2013 17:02

March 27, 2013

Contents of a Film Private Placement Memorandum

Below is Part 2 of 4 in my PPM series on FilmProposals.com:


Now that you know what a Private Placement Memorandum is, and how it can help you raise money from Film Investors, let’s look at the contents of a Film PPM. There are 10 sections that make up your independent film PPM. The first section of the document, Summary of the Offering, is the most comprehensive and will be the first impression you make with film investors. It is where you first outline your Company, Film and Financial details.


The following represents a list of all of the details that make up your Summary of the Offering:


Company Details

Name of offering entity (LP, LLC or corporation)


Contact Information

Address

Phone Number and Fax Number

Email Address


State in which entity is formed (or to be formed)


If already formed, date of formation

If not formed, will it be formed before or after start of offering


Purpose of Offering Entity

For most of you, the production of a feature film


Film Details

Name of Film

If this is a working title, you should specify this


Screenplay Writer(s)


Director


Producer(s)

This includes Executive Producers as well


Any Cast attached


Financial Details

Size of Unit

($ per unit, interest or share)


Number of units to be sold


Size of total offering

Size of minimum investment


Payback %’s to investors (if applicable)


Any interest payable to investors (if applicable)


Is the offer available to non-accredited investors?


Impound or non-impound

(money escrowed until certain level of investment reached)


Commissions and/or Fees (due diligence fees and finders fees)


A list of any selling brokers


Is there a selling agreement with a broker?


States, Countries where Units are offered


Name of Manager(s) and position(s)


If Manager is an entity, the Owner and operator of Manager


Are resumes available for people mentioned above


If this is an existing entity, divulge any info on prior projects (that are related to the offering)


Businesses, financial data, copy of all governing documents


Identity of any predecessor entities and some summary info regarding how much money raised and what proceeds used for.


If the offering entity already exists, do they have any financial statements?


If the manager of the offering entity is an entity itself, are there any financial statements for it?



Conclusion

Although this is just the first section of the PPM, if you can answer the majority of these questions, then chances are, you are ready to put together a meaningful business proposal for your film. If you aren’t sure about these questions, or are on the fence about certain answers, then you are NOT ready to approach investors about your film. You may have a screenplay you believe in, but you do not yet have a clear financial plan. Nor will you be able to respond to a savvy investor who will ask you these questions.


Do not despair, answers to your questions are out there. Or, if you know the answer and just happen to be on the fence about one of the questions – there are people out there willing to share their experiences and knowledge with you.  However, they are not lining up to come to you. If you are making an independent film, it is time to get in that mindset – which means YOU need to make it happen. Seek these answers and experienced producers out.  And never get discouraged by a cold shoulder or a negative response. All it takes is one positive response.



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Published on March 27, 2013 08:00

March 25, 2013

Lunatic Has Been Approved!

It came over a month later than everyone expected, but my next feature film, LUNATIC, has finally received approval for the UK tax incentive.  Apparently they wanted a lot more documentation than previous years and it slowed things down a bit.  But we are now approved and can take final steps towards locking in financing and legal.


I am keeping myself on an even keel until that process is finalized because anything can happen between now and then.  However, the shoot date has been set in June and the powers that be are all gunning to make that happen.  I continue to do as much as I can and am way ahead of the curve in terms of where I need to be.


Lunatic-Werewolf Test



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Published on March 25, 2013 08:03

March 22, 2013

What is a PPM (and how does it affect your film)?

Since my surgery I’ve been on the shelf for a while.  I’m starting to come around and I have recently been consulting with FilmProposals.com - writing articles, revising some of their data, reviewing business proposals for films, etc…


Below is the first of four in my series on Private Placement Memorandum’s for feature films:


If you are looking to raise money for your independent film, you have likely heard the term Private Placement Memorandum (PPM) and are wondering if you need one? Unless you are getting private equity from family and friends, you should have a Film Private Placement Memorandum (PPM) drawn up for your fund raising.  In fact, you should have a PPM even if that is the case.


What is a PPM?


PPM stands for Private Placement Memorandum. Issuing a PPM lets your company sell shares to “passive investors” (those who invest but take no active role in the production) in order to raise the money needed for the film project.


This document commonly provides investors with material information, such as a description of the company’s business, financial statements, biographies of officers and directors, detailed information about their compensation, any litigation that is taking place, a list of material properties and any other material information.


How does a PPM affect your independent film?


Having a PPM is just as much for your protection as it is for your investors. The primary purpose of a PPM is to give producers the opportunity to present all potential risks to potential investors (such as the inability to find distribution or that it may never achieve financial success), thus making it difficult for investors to claim that they were not adequately warned. For this reason, it is vital the contents of the PPM be accurate and complete and meet the highest standards of full disclosure (under securities laws) to potential investors.


In drawing up a PPM, be aware of the type of film you are making. This honesty will protect you later on.  Do not oversell your film.  If you are making a low budget independent film that will more than likely be taken to a sales market or film festival, your PPM should not focus on theatrical releases (their numbers and risk factors). When using comparable films or revenue projections be as conservative as possible. For example, your found footage film should not reference Blair Witch Project and/or Paranormal Activity.  Also, don’t use sequels or franchises when putting numbers together because they will obviously skew your numbers.


Where can I get a PPM done?


Most of us don’t have access to investment banks, so entertainment law firms are a good place to start.  These are in the $10,000 range, but could run you as much as $20,000. This could very well be an astronomical number, and would defeat the purpose of trying to raise this money. Don’t despair, there are firms that specialize in PPM’s online for a fraction of the price. However, before doing business with them, make sure that they have adequate experience in films.


The PPM does not have to be written by an attorney, but must be reviewed by a qualified attorney to assure it complies with all national and state regulations.


Stay tuned for the next article in our 4 Part Series: What Goes Into a PPM?


 



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Published on March 22, 2013 08:57