January 26, 2011
I am writing in response to your request for comment on File No. S7-04-11 regarding the new proposed Net Worth Standard for Accredited Investors Under Dodd-Frank Act. I should like to applaud the Commission and Chairman Schapiro for raising the accredited investor threshold via the exclusion of primary residence net value for the purposes of net worth calculation. As a successful sixth generation industrial magnate, I find it disheartening that so many troglodytes of mean birth skirt the spirit, if not the letter, of the law by aping their social superiors in the accumulation of "home ownership." Am I believe that Johnny Day Laborer's million dollar "handyman special" pied a terre allows his vacuous mind to comprehend the role of theta decay in naked split-strike conversion straddles?
There are two loopholes which I believe the Commission should attend to post-haste. The first is the issue of homeless millionaires. Excluding primary residence value, even adjusted for outstanding mortgages, will still allow homeless millionaires to qualify as accredited investors, defying the intent of Dodd-Frank. The phenomenon is far more common than is generally recognized. I have had numerous associates at my firm, millionaires all yet less men than I, forsake their primary residences merely to avoid our HR office's policy of droit de seigneur upon successful completion of the rotational training program. I shudder to think how they would have coped with the frottage involved in our ius secondae noctis.
The second loophole involved what is colloquially known as "gangsta grillz." In this manoeuver, in lieu of fee simple real estate ownership, the putative accredited investor seeks to evade the intent of the law via dental implants of gold, blood diamonds, rare earth metals, and sundry other geological oddities of mineral wealth. Without strict regulation on this point, the financial community may need to resort to a two drink minimum with mandatory 18% tip in order to keep the riff-raff out. I trust I have made myself clear.