Subject: Comment - Broadening of Accredited Investor Definition
From: Luke Denlinger

Dec. 22, 2019



Regarding the recent proposal to broaden the criteria used for the accredited investor definition - first and foremost I want to applaud this effort. It's a long overdue update that will provide opportunities for knowledgeable individuals to more fully participate in our financial markets. 


With that said, I'm surprised to see that CFA charterholders were not also included in the list of examples provided for potential investors to be included. As I'm sure you're aware, the CFA curriculum and continuing education program carry a strong reputation in the financial world and obtaining the charter is considered extremely difficult. I believe it would be a huge oversight to exclude CFA charterholders while including investors that have passed different Series exams.  


Best regards, 
Luke Denlinger, CFA