September 24, 2013
I would like to take this opportunity to support the suggestions and comments made by the National Investment Bankers Association. The responsible expansion of the Accredited Investor base by allowing for smaller investments as a percentage of net worth or income from a larger base of qualified investors is a more important consideration than all of the other 506 (c) issues, and will have a greater impact on capital formation than any other proposals to date.
The overwhelming support and opposition of other 506 issues have also been adequately transmitted by parts of the SIFMA letter covering 506 issues (although we disagree with their position on Accredited Investors as being part of yesterday's thinking instead of tomorrow's mandates) and other significant organizations, so we too urge the Commission to follow the cumulative suggestions of virtually all commentators related to 506 revisions. As Proposed, the Commission's Proposals will not result in effective progress.