January 26, 2007
To Whom It May Concern,
I would like to suggest some other method of limiting investment access to private funds, rather than increasing the minimum net worth requirement from $1,000,000 to $2,500,000. As a financial planner, I see clients with a net worth greater than $2,500,000 who are less sophisticated investors than those with less than $100,000. Net worth is a poor criteria for judging investor sophistication.
I believe investors advised by a professional financial planner (e.g. those designated as CERTIFIED FINANCIAL PLANNER(tm) professionals,) should be permitted to invest in private funds if the planner judges it to be appropriate. These funds can be used as part of a prudent diversification strategy, especially as investors approach retirement. Ask those who lost a significant portion of their retirement savings in the 2000-2003 bear market if investment in private funds would have been of benefit. Of course, a CERTIFIED FINANCIAL PLANNER(tm) professional should also be exempt.
I also disagree with the elimination of the $200,000/$300,000 income rule. For instance, I have a young couple as a client. They are both doctors and earn in excess of $400,000 per year, but since they are just starting out, their net worth will not exceed $2,500,000 for many years. Yet, their capacity for risk is much greater than the recently retired couple with a $3,000,000 portfolio and spending levels of $150,000 per year.