Subject: Amending the “Accredited Investor” Definition
From: Einar Vollset
Affiliation: General Partner, Tinyseed.com

December 18, 2019




I believe the proposed amendments insufficiently broadens the definition of accredited investor. From my perspective, a natural person should be free to make high risk bets with their own money, as long as they understand those risks.  


Requiring highly expensive and specialized professional certifications such as Series 7, 65 or 82 is completely pointless exercise. Individual investors are currently permitted to gamble away whatever they like via options trading on easy to use platforms such as RobinHood without any education what so ever, and while I do not think that adopting that stance is appropriate, an approach that doesn’t simply seem like inside baseball for Wall St makes sense. Specifically I propose one of the following two options: 


People should be free to invest a percentage of their net worth into private funds, whatever their wealth, and/or People should be free to invest whatever they like, assuming they have passed a basic exam proving an understanding of the risks involved (Note: NOT Series 7, 65 or 82. That’s just a gimme to the private education companies specializing in those exams, and likely would cost more to obtain than a lot of people are willing to invest.). 


Sincerely, 


Dr Einar Vollset 
Santa Cruz, California, CA. 



General Partner 
TinySeed.com