Subject: File No. S7-06-13
From: Dan Blake
Affiliation: Director, Wisconsin Angel Network

June 10, 2014

Dear Chairwoman White:

   Thank you for the opportunity to provide comments regarding the
   ongoing Securities and Exchange Commission review of the accredited
   investor standard.

   The Wisconsin Angel Network is an umbrella organization that
   represents and supports angel investors, networks and funds that
   provide capital to entrepreneurs in Wisconsin and elsewhere. As
   director of the organization, along with the groups signed on to this
   letter, we urge the Commission to protect angel funding by keeping in
   place the existing financial thresholds in the current accredited
   investor definition.

   The current thresholds of $1 million in net worth or $200,000 in
   income has worked well for decades and led to the growth of more than
   20 early stage investment groups in Wisconsin alone, and millions in
   funding to state entrepreneurs over time. Angel investors are a major
   source of funds for companies that drive the innovation economy and
   job-creation nationwide, and do so with very little fraud involved.

   If the financial limits were increased, angel investment in
   early-stage companies would suffer. An increase in the net worth
   threshold to $2.5 million, advocated by some, could cut upwards of a
   third of current accredited investors out of some markets, according
   to the Angel Capital Association, of which we are affiliate members.

   Such an action would cause a significant reduction in the number of
   accredited investors, especially in places such as Wisconsin, where
   the prevalence of large amounts of wealth is not as common as some
   other parts of the country. It would also cause issues for
   entrepreneurs in a state where venture capital is not as prevalent. A
   contraction in angel investing could also stall local economic
   development, university technology initiatives, and stem innovation
   and job growth. In short, a higher threshold would widen the flyover
   state funding gap.

   Angel investors have been growing in number across the country and the
   activity has been largely free of fraud. Often, this is related to the
   hands-on approach many individual angels and groups, including those
   in Wisconsin, have in advising and mentoring the entrepreneurs they
   back. Because of the importance of angel investing to job growth, and
   the future of the United States economy, we urge the Commission to
   maintain the current thresholds for accredited investor

   Keeping the current thresholds would continue to recognize the vital
   role sophisticated investors can have in supporting innovation and
   economic growth in places like Wisconsin and across the United States.

   Thank you for your consideration.


   Dan Blake
   Director, Wisconsin Angel Network (Madison)

   Additional support:

   Golden Angels Investors
   Wisconsin Investment Partners
   Chippewa Valley Angel Investor Network
   Shannon/Harris Shamrock
   Angels on the Water
   Northwoods Angels
   New Richmond Angel Investor Network
   Yahara Angels Network