Subject: File No. S7-06-13
From: Nate Doran
Affiliation: Entrepreneur Director, Keiretsu Forum NW

June 27, 2014

No bank loans, SBA loans, nor VC funding cover the space that Angels fill in the economy right now - based upon the current definition of an accredited investor. Further, VCs tend to chase after highly abstract and out-there technologies, they tend to fire CEO's and liquidate businesses for the interests of their own LPs, whereas Angels invest in real local businesses that create local jobs and make a difference in their own local economies. Angel portfolios above 10 companies return a 2.5x at angel groups, and up to 5x for portfolios where angels have invested 40 hours of due diligence in each company.

The amount of wealth an investor has, has nothing to do with the sophistication of that investor and his/her ability to judge whether a company is worth investing in. So, this cannot be used as a basis for any argument made to justify any number. Someone worth $10 million can be just as unsophisticated as someone worth $10. The government shouldn't be expected to protect people from risk-taking in the private sector.

Active angels are a small % of those who currently qualify as accredited. Cutting this number in half will hurt everyone on arbitrary grounds.