That is correct, but the difference between the instruments is not relevant to my statement. I bought restricted stock when I founded a company, which vested over four years, and have taken options when joining as an employee. Almost chose to do an 83b election on my options  using a loan from a startup I joined, in order to improve my tems, but I am happy I did not do so. Considering the risk of failure it is generally advisable to diversify your investments more than that.<p>Edit: rdl , for the loan from the company to do the 83b election to be a considered a loan by the irs it must have almost full recourse. You will be liable for it and the creditors will ask for the loan amount in case of failure.