Subject: File No. S7-06-13
From: Norberto Ballesteros
Affiliation: C.T. Bauer College of Business, University of Houston

October 22, 2018

Net Worth and Income have no causal relationship to Investment sophistication. It is my sincere desire that the definition of an Accredited Investor be changed to reflect that.
I argue that the current minimum threshold to be considered accredited are somewhat arbitrary.
By restricting the sale of private securities to "Accredited Investors" the current act is prohibiting sophisticated, but non-accredited investors from accessing what are potentially suitable investments for them.
The existing rules addressing "Suitability" are more than enough to address any investment: public or private.