Subject: File No. 4-932
From: David A. Rooney

I hold RI CPA Certificate issued in 1968. I fully retired from public practice in 2013 after more than 40 years of public accounting practice. I no longer have a "permit" to practice public accounting but I am still a CPA. I cannot hold myself out to the public as a practicing CPA but I will be a CPA until I die or the RI Board of Accountancy revokes my CPA certificate for cause, such as a felony conviction. I can assure you, after more than 40 years of public practice, I knew a hell of a lot more about financial risk assessment in general and investment risk assessment at the end of my public accounting career than I did when I first held a CPA certificate. I will add that wisdom continues to today as my full time day job now is investing in and trading marketable securities. I know more about investing now than I did when I retired. Notwithstanding the wisdom from experience, in my opinion, any person holding a CPA certificate should be presumed to be an accredited investor. If they act like a dummy, it's their own fault. Nevertheless, young people do stupid things like taking on a risk they cannot afford to lose. When such a person suffers a loss, they pay "tuition" (the loss) and hopefully, the "tuition" makes the lesson learned a permanent one. You cannot regulate away "stupid". I favor presuming a CPA is an accredited investor. David A Rooney, CPA (retired)