December 18, 2019
Thank you for the press release today. Here are some considerations. · add new categories to the definition that would permit natural persons to qualify as accredited investors based on certain professional certifications and designations, such as a Series 7, 65 or 82 license, or other credentials issued by an accredited educational institution. COULD THIS BE EXPANDED TO ALLOW THE NATURAL PERSON TO BE CONSIDERED A QUALIFIED PURCHASER AS WELL? · with respect to investments in a private fund, add a new category based on the person’s status as a “knowledgeable employee” of the fund; COULD THIS BE EXPANDED TO ALLOW THE KNOWLEDGEABLE EMPLOYEE TO BE CONSIDERED A QUALIFIED PURCHASER AS WELL? MOST PRIVATE FUNDS REQUIRE THE INVESTOR TO BE BOTH AN ACRREDITED INVESTOR AND QUALIFIED PURCHASER. · add limited liability companies that meet certain conditions, registered investment advisers and rural business investment companies (RBICs) to the current list of entities that may qualify as accredited investors; COULD THIS BE EXPANDED TO ALLOW NATURAL PERSONS ADVISED BY ANY REGISTERED INVESTMENT ADVISER TO BE CONSIDERED ACCREDITED INVESTORS AND QUALIFIED PURCHASERS? FURTHER A LETTER FROM THE RIA OF THE RIA ENGAGEMENT WITH THE CLIENT SHOULD SUFFICE AS EVIDENCE OF SUCH. · add a new category for any entity, including Indian tribes, owning “investments,” as defined in Rule 2a51-1(b) under the Investment Company Act, in excess of $5 million and that was not formed for the specific purpose of investing in the securities offered; NO COMMENT · add “family offices” with at least $5 million in assets under management and their “family clients,” as each term is defined under the Investment Advisers Act; and COULD THIS BE EXPANDED TO ALLOW THE FAMILY OFFICE AND THEIR FAMILY OFFICE CLIENTS TO BE CONSIDERED QUALIFIED PURCHASERS AS WELL? · add the term “spousal equivalent” to the accredited investor definition, so that spousal equivalents may pool their finances for the purpose of qualifying as accredited investors. COULD THIS BE EXPANDED TO ALLOW THE NATURAL PERSON TO BE CONSIDERED A QUALIFIED PURCHASER AS WELL? Regards, Rafay Rafay H. Farooqui Chief Executive Officer SAF PLATFORM 902 Broadway, Suite 1611 New York, NY 10010 [redacted] www.safplatform.com Securities offered through SAF Financial Securities LLC, member FINRA / SIPC. Disclaimer