Subject: Comments on Amending the “Accredited Investor” Definition (Rule S7-25-19)
From: Davis Treybig

December 20, 2019

I would like to provide comments to the recent "Amending the “Accredited Investor” Definition" fact sheet published by the SEC. In particular, I would like to comment on the following highlight in the document: 

"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;" 

To me, this is by far the most important change to be made to the accredited investor designation. Wealth should not be used as the primary corollary for "sophistication", and it's critical that any American who is willing to spend the time to study and learn about security offerings can do so regardless of their economic status. Preferably, such a test or certification should be accessible to anyone, without needing to go to a specific college or pay substantial amounts of money.  

As more and more wealth creation moves to the private markets (e.g. see the average startup staying private for nearly 10+ years before IPO now), it's imperative we democratize access to security offerings. If we want to maintain the idea of the American Dream, we can't shut off the best performing asset classes to only the wealthiest in America.