Subject: File No. S7-08-19
From: Shanel S Fields
Affiliation: CEO

December 28, 2019

'Spousal Equivalent' could be expanded to 'Kin Equivalent' so that families/relatives "may pool their finances for the purpose of qualifying as accredited investors." Highly-educated and/or high-net-worth individuals that earn enough to qualify as accredited, have received "credentials issued by an accredited educational institution" or are experienced enough to be considered a "knowledgeable employee" can assist their family members in making sound investment decisions. This would both extend the reach of successful investments made within those families and minimize each individual's financial risk.