Subject: File No. S7-06-13
From: Kevin H. Pollard
Affiliation: Managing Partner and President
GlobalSolve Management Services, LLC

June 17, 2014

Elizabeth M. Murphy
Securities and Exchange Commission,
100 F Street NE
Washington, DC 20549–1090

Via email to

Re: Amendments to Regulation D, Form D and Rule 156 under the Securities Act

Dear Ms. Murphy:

Please do not believe everything that you hear from the AARP and other organizations that claim that their intentions are “to protect the ignorant” from flim-flam entrepreneurs, who would bilk them of their money.
I am 66 years old and, because I choose, I make less than $200,000 per year; I don’t need to make any more money because I have no debt, including my home. I have a net worth in my investment portfolio of $2+ million and have a retirement income which I receive every month.

Under the rules for consideration at this time, I would not qualify as an angel investor; I am a sophisticated investor, former entrepreneur, former public company executive, international business board director, and an investor in an angel fund as well as an investor in an angel network.

These proposed changes are poorly thought-through, as much of Dodd-Frank was thoroughly ignorant of what really happens out in the real world.
I urge you to hold the current definition of angel investor and its qualifications exactly where it is now; if you do change the definition of qualified investors, you will have two unintended consequences:

  1. The entrepreneurial community will lose an estimated one-third to one-half of the angel investor community.
  2. As a result, more deals will chase fewer dollars for investment, which will drive the value of the investor up and choke the entrepreneur.

The result will be the loss of a large part of the entrepreneurial economic backbone of our country, one of the unique dimensions of the U.S.; we need to be creating new jobs at this time, not losing them.

Please keep the current definitions of qualified investors intact without changes.

Thank you,

With kindest regards,