Subject: File No. S7-06-13
From: Doug Ramler

July 10, 2014

Representatives of the SEC:

I agree with the comment submitted by Kiran Lingam at SeedInvest on July 8, 2014 available at that raising the accredited investor thresholds would be disastrous for startups, job creation and the U.S. economy.  I believe the SEC should refrain from increasing these thresholds and should also adopt knowledge/experience based standards for an individual to become an accredited investor.

Over the past three years I have made five investments totaling approximately $120,000 in very early stage companies, and plan to continue to invest in the future. I have worked with entrepreneurs throughout my career and understand the need for early-stage capital. If the threshold changes are enacted, I will likley no longer be an accredited investor. In addition to ceasing my direct investing efforts, I will also be required to resign from a large national angel group for failure to meet the accredited investor qualifications. I estimate that approximately one half of the members of this group will also be forced to resign for failure to meet qualifications. That national angel group has invested more than $3 million over the past two years in startup companies. The proposed changes are unnecessary and will be counterproductive.

Doug Ramler,
Plymouth, MN
Individual Investor
Bermuda Group, LLC Member
Irish Angels Member