Subject: File No. S7-04-11
From: Joe Tinger
Affiliation: an analyst and consultant

January 26, 2011

After reading the proposed ammendment of the definition toward 'accredited investor' there are two areas that may have been an oversight as any new 'Bill' shall go through the implementation phase and any fault areas may be revealed. The two areas are

1. Enforcement shall be laxed until a comprehensive review is completed as outlined in section 413(a), e.g. 2014 review process.

2. Net worth of items used for 'private use' should be exempt due to the nature of the definition.

2A. An 'accredited investor' should meet the requirements of investments for business purpose and not the proposed amendment for personal gain of personal items such as a residence. However, a percentage of their personal finances could be used.