February 13, 2007
Subject: File No. S7-25-06
From: Steven Kaye CFP.CLU,ChFC,CEBS,RHU,CRC
Affiliation: American Economic Planning Group, Inc.February 13, 2007
Please consider adding another exemption to your proposed category of "accredited natural person". I suggest adding an exemption (from the proposed $2.5 million asset requirement) for investors who:
1. are already accredited (Rule 501(a) of Reg D), and
2. have completed a comprehensive personal financial plan with a Certified Financial Planner, and,
3. have retained a registered investment advisor that always maintains a fiduciary relationship with the investor, and
4. have retained a registered investment advisor that maintains robust professional credentials (ie CFA, CFP, or CPA), and
5. have retained a registered investment advisor that uses technology sophisticated enough to forecast a reduction of overall risk levels in client portfolios when the portfolios include some alternative investments.
6. or, clients who have invested in alternatives in the past
7. Or , clients who have owned businesses for more than 5 years .
The rules are very arbitrary.
Thank you for your consideration.