August 30, 2012
While we welcome the opportunity to make what would normally be limited availability private placements more widely available to the public and we understand and accept the responsibility to verify that investors meet the accredited investor test, we are still befuddled by a hole in the rules which does not acknowledge that an accredited investor remains an accredited investor whether he funds his investment through his own personal accredited account or joint account with an otherwise non-accredited spouse or through a non-accredited source of which he/she is the conservator or only managing person such as a family trust, personal trust, llc or sub-s corporation. We believe that the subscriber or decision maker should be the determinant of accredited investor status and not the source of the funds used to effect the transaction. We would very much appreciate your rethinking this inconsistency.