December 18, 2019
To Whom it May Concern, I want to express my support with the SEC's consideration in the amendment of the Accredited Investor definition. As a finance professional in the asset management industry, I find the current definition to be punitive to those that don't clear lofty financial hurdles such as 200k/year or 1mm net worth outside personal residence. As per the current definition, a widow that inherits $1,000,001 from their late spouse is more "accredited" than myself, an individual that professionally underwrites and structures financial products backed by collateral in excess of $100mm... You can see where I see the disconnect. My comments for the updated definition re finance professionals, are, in addition to the credentials listed in the amended definition, professionals with experience demonstrating an understanding of the investment process. While the certifications are an easy way to monitor the legitimacy, there are thousands other finance/accounting professionals who may be more equipped to understand a private offering. Another option, which would require minimal resources by the Commission yet still be easily verifiable, would be for the Commission to require an individual self-certify professional experience by providing the firm and position held. Similar to availability to review an individuals financial certifications, the Commission could review an individuals' professional experience, if necessary, via tax returns, employment history etc. I understand and respect the protections put in place by the SEC to protect ordinary individuals from the "snake oil" salesmen of the world. However, I believe there needs to be additional options for those that understand the risks within these investments. There are great opportunities out there which i have had to pass on because I am not yet fortunate to clear the thresholds as currently defined. Thank you for the consideration and allowing me to voice my feedback. Malcolm Douglas [redacted]