Subject: File No. S7-05-20
From: Michael Seng, CPA

March 10, 2020

Sirs and Madams of the SEC,

I am writing since I am confused when the accredited investor definition was not broadened to include professional designations as originally proposed. I supported professional designations comments made by others previously for both their professions or all profession designations. Since I am a CPA I can best make this case, although think others should be considered.

CPAs are relied upon for their expertise and are there from the beginning when an idea is turned into a proposal for investors. We create the financial statements and proforma investment documents including risk disclosures for potential investment to be analyzed by investors. CPAs audit the financial statements to ensure that they are accurate and include all appropriate disclosures so that investors have a clear understanding of their investments performance. CPAs help with tax planning and tax preparation for both the investment as well as the investors. CPAs are an important part from inception all the way through, touching each step and helping understand the investment at each step. To be this invloved at each step and having our professional designation mean so much when we sign off, the CPA designation shows we understand the risk of an investment.

Thank you for taking the time to read my comments and for taking the time to reconsider adding the CPA designation to the accredited investor definition.

Michael Seng