Subject: File No. 4-931
From: USAF

I support creating a pathway for individuals to qualify as accredited investors by demonstrating financial knowledge and sophistication rather than relying only on income or net-worth thresholds. I am a retired military member who receives military retirement and VA compensation and now also works in a high-income civilian position. Because my military and VA income already cover much of my household needs, I am able to invest a substantial portion of my civilian income. In practical terms, I have significant disposable and investable income and can absorb the loss of a private investment without affecting my financial security. However, the current accredited-investor framework does not necessarily capture situations like mine very well. A fixed national income threshold does not account for differences in cost of living, guaranteed retirement income, tax-exempt income, household debt, or actual disposable income. Someone earning slightly more than $200,000 in a high-cost area with significant expenses may qualify, while someone in a lower-cost community with substantially greater financial flexibility may not. I believe this issue may be particularly relevant in military communities. Many retired service members receive military retirement and VA compensation and later move into well-paying second careers in defense, technology, engineering, program management, and other professional fields. Some may have substantial capital available for investment even though they do not fit the traditional accredited-investor profile. This matters not only for individual investors, but also for local economic development. In communities like the Black Hills of South Dakota, there may be a meaningful but largely untapped population of potential angel investors who want to support local startups, veteran-owned businesses, and emerging technology companies. Allowing financially sophisticated individuals to qualify through an examination could help unlock that capital while still maintaining investor protections. For these reasons, I support an accredited-investor examination as an additional pathway to qualification. I believe demonstrated knowledge of private-market risks, securities structures, dilution, illiquidity, financial statements, and investor rights can be a more meaningful measure of preparedness than income alone. I encourage the Commission to adopt a framework that allows individuals to demonstrate competence and understanding rather than using wealth or income as the primary gatekeeper to private-market investment opportunities.