Subject: File No. S7-07-12
From: Michael R Witulski, Witulski
Affiliation: Business Developement,

September 5, 2012

We are also concerned that a prescriptive rule that specifies required verification methods could be overly burdensome in some cases, by requiring issuers to follow the same steps, regardless of their particular circumstances, and ineffective in others, by requiring steps that, in the particular circumstances, would not actually verify accredited investor status.

I have found that the "Idle Rich" are not willing to share much information in today's economy. I believe a form that includes a potential investors statement of income and net worth, would be much more practical.