Subject: S7-25-19 Comment
From: Hunter Todd

December 19, 2019


I strongly encourage and support an evolution in the Accredited Investor definition. I previously participated in fundraising for a business, which raised money from venture firms and high net worth individuals. Relying on wealth as a proxy for investment sophistication is rash. 


Anecdotally, I observed many seemingly "Accredited Investors" invest with limited questioning and scant diligence. Oftentimes, these wealthy individual's did not earn their income through sophisticated investing strategies, rather it stemmed from family investments or other passive sources that were not of their own achievement. Therefore, while they met the wealth standards, they were far less sophisticated. However, their risk tolerance was likely much higher.  


I would encourage those who can demonstrate experience in investments to meet the definition of Accredited Investor. Granted, this is significantly more challenging to objectively measure. However, if someone works at a firm with a demonstrated track record of successful investments for >x years, that should be verifiable via W2 statements.  


Appreciate your consideration of one lowly man's opinion.  


Best regards, 
Hunter