October 5, 2012
I noticed the comments by the State Corporation Commission of the Commonwealth of Virginia. They seem overly concerned about investor protection and seem to want an overly complicated process for verifying that investors are accredited. I wonder what process Virginia has in place to ensure that the buyers of their state-sponsored lottery tickets are accredited? Well, they don't require people who invest their money in lottery tickets to be accredited, although over time, these investors are almost certain to lose all of their money investing in these lottery tickets. I guess the reason Virgina doesn't require investors in their state-sponsored lottery tickets to be accredited is because this would be discrimination and limits the freedoms of the investors. Yet, they seem willing to limit the freedoms of businesses and investors, by requiring an overly complicated verification process. The SEC should implement its proposal immediately and provide a safe harbor to issuers that allows self-certification by investors. Nothing could be more "reasonable" than self-certification.