Subject: File No. S7-06-13
From: Kriss Kirchhoff
Affiliation: President Boise Angel Alliance

August 15, 2013

In a perfect world an accreditation test would include investment experience, risk tolerance, and net worth.

Incorporating all of these factors, however, would be burdensome in practical application.

The current process of self-accreditation based on net-worth and income is fine but could be improved by basing the test solely on net-worth as income does not consider debt and expense obligations that may impair an individual's ability to make the risky investment.