I appreciate the opportunity to comment on the Commission’s consideration of whether to designate a U.S. certified public accountant license in good standing as a qualification for accredited-investor status. I support the Commission’s proposal and encourage the Commission to adopt it. More broadly, I believe the accredited-investor framework should place substantially greater emphasis on demonstrated knowledge and qualifications, rather than wealth or income. The current monetary thresholds are an unnecessarily crude measure of financial sophistication. A person’s income or net worth does not reliably establish whether that person understands securities, investment risks, private offerings, or the consequences of a potential loss. At the same time, those thresholds exclude individuals who may have the knowledge and experience necessary to evaluate private-market investments but who do not meet an arbitrary financial test. The rules should respect an individual’s autonomy and ability to make personal financial decisions. The government generally need not—and should not—protect competent adults from every risk associated with their own voluntary investment decisions. Investors should receive clear and accurate information, but access to investment opportunities should not depend solely on whether the government determines that they are sufficiently wealthy. A qualifications-based approach is more rational than the current wealth-based approach. Professional credentials such as the CPA license, CFA designation, CFP certification, and comparable qualifications can provide meaningful evidence of education, examination, professional competence, and financial sophistication. I therefore support adding qualifying CPA license holders and other appropriately vetted credential holders to the accredited-investor category, subject to reasonable requirements that the credential remain active and in good standing. The Commission should also consider creating an accredited-investor examination that any adult investor could take. The examination could test a person’s understanding of securities, private offerings, investment structures, valuation, liquidity limitations, fees, conflicts of interest, disclosure limitations, and the possibility of losing some or all of the investment. An exam-based pathway would allow individuals to demonstrate relevant knowledge directly, without requiring them to satisfy an income or net-worth threshold or obtain a particular professional credential. To be effective, the examination should be reasonably accessible, administered by an independent and qualified entity, and available on a recurring basis. The Commission could establish minimum content and testing standards while permitting qualified third parties to administer the examination. The exam should measure investment knowledge and risk comprehension—not wealth, occupation, or social status. In summary, I respectfully encourage the Commission to: Designate an active U.S. CPA license in good standing as a qualifying credential for accredited-investor status; Designate other relevant and rigorously administered professional credentials, including the CFA and CFP designations, where they demonstrate sufficient financial knowledge and sophistication; and Establish an additional pathway under which any adult investor may qualify by passing a standardized accredited-investor examination. A framework based on knowledge, qualifications, and demonstrated understanding would be more closely aligned with the purpose of accredited-investor regulation than the current system’s reliance on wealth and income. It would expand investor choice while preserving an appropriate focus on informed decision-making and investor awareness of risk. Thank you for considering these comments.