Subject: File No. S7-06-13
From: David Lambert
Affiliation: Managing Director, Right Side Capital Management

May 22, 2014

I am a career entrepreneur, a long time angel investor, and now a professional seed stage technology investor. My entire adult life has involved raising money from, and investing alongside, accredited investors.

If the qualifications for being an accredited investor are raised substantially from their current requirements, I have not doubt that the effects will be completely devastating to the U.S. entrepreneurial ecology.

Accredited investors are the lifeblood that keeps innovative young startups alive, and these startups are the job creation engine that keeps our economy humming. The proposed changes would entirely gut the startup ecosystem in this country. It is bad for everyone.

Furthermore, the assumption that investors with more money are more sophisticated is archaic. It might have been true in the 1950s, but it certainly is not the case today. I deal with investors all day long and I see absolutely no correlation to the amount of wealth an investor has and his or her level of investor sophistication. If anything, I think their might be an inverse correlation. I also find it morally offensive that the government would tell an adult investor that has accumulated over $1M in wealth what they can and cannot do with their money.

The proposed regulation will destroy the entrepreneurial spirit that has made this country the greatest on earth. Please don't do it