July 25, 2013
The proposed rules on public general solicitation contain a flaw that needs to be amended before the rules become final.
Under the provisions for third party verification, the rules note that among advisors, only SEC registered investment advisors may perform this verification.
There is no public purpose or logic to excluding state registered advisors from performing this verification task.
Please amend the text of the proposed rules to state that state registered advisors can perform third party verification of the status of an accredited investor.