Subject: File No. 4-692
From: Kyle Beagle
Affiliation: Small business advisor

January 13, 2016

Hearing from companies constantly about how hard it is to attract and find funding outside of silicon valley do to the hardship of finding accredited investors based on the current definition I think the definition needs to be revised to include the following.

3 levels for individuals
Non-accredited (can in vest up to certain limits in private offerings with proper disclosure)

Partially accredited (consist of investors who have proven a knowledge of risk associated with private offerings either through experience, professional designation, or a knowledge based exam.) These people would be able to invest in any offering as to a percentage threshold of worth or income as not the take on too much risk)

Fully accredited investors (invests who based on income and net worth have the wear with all to with stand substantial risk and have no limits on investments) (would comply with current definition of accredited investor)

For Companies:
Accredited investors should be based on total company value and or knowledge of representatives making the investment in the non public offering and should cover all types of companies. This allows for more forms of private investment and ways for larger companies to play a role in helping smaller companies even if that is not their core industry.

For offerings: offerings shall be able to be made by any legitimate company who is willing to provide the proper disclosure for the level of investors being sought. This includes all industries and funds. The funds offerings would especially beneficial to smaller investors as they would allow them to diversify in this new market by buying slices of different hedge and start up type funds.