Subject: File No. S7-06-13
From: Donald Gooding
Affiliation: Vice Chair, Maine Angels

June 9, 2014

It has come to my attention that the SEC is considering raising the standards of accredited investors from the current reasonable levels of wealth or income, to as much as 2.5X those levels.

This is a very bad idea.

First, there is no evidence that this solves a problem. All of us helping entrepreneurs tell them to focus on solving a problem, and there is no evidence that fraud against currently accredited investors is an issue, or that lack of investment sophistication is an issue. Instead, this unnecessary change to regulation will cause economic problems by dramatically reducing available angel investment capital.

Second, this move goes directly against the spirit of the JOBS act, which was to increase the amount of capital available for America's small businesses. The regulatory change reduces, not increases, the capital available.

Third, this change would deny some portion of angel investors, including me, the opportunity to complete our portfolios. Diversification of angel portfolios is critical to achieving financial success mine is not yet sufficiently diversified. If these regulations change I will no longer be able to continue investing as I will be no longer an accredited investor, despite having been with a top tier venture capital firm for 11 years, and acting as an angel investor for 15 years including 2+ years in leadership for an angel investor group. Thanks, but I don't need your protection.


Don Gooding