July 10, 2014
Representatives of the SEC:
I agree with the comment submitted by Kiran Lingam at SeedInvest on July 8, 2014 available at http://www.sec.gov/comments/s7-06-13/s70613-546.pdf 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.
Bermuda Group, LLC Member
Irish Angels Member