September 5, 2013
The income and asset tests used to qualify individuals as accredited investors are crude. An individual with little or no debt, in good health, with few or no dependents and a simple lifestyle cannot be considered comparable to a couple with debt, health care expenses, dependents and an extravagant life style even though the household incomes and net worths may be the same. Somehow the SEC needs to base accredited investor qualifications upon disposable income and/or assets.