Subject: File No. S7-25-19
From: Alan Donenfeld, Founder and CEO
Affiliation: CITYVEST

January 6, 2020

 


The million dollar net worth test penalizes someone with say $500,000 in net worth from investing in a real estate private placement.  I would like to see a junior level Accredited Investor, that might be called a Knowledgeable Investor, Certified Investor or an Experienced Investor.  This lower level Accredited Investor may earn a minimum of $100,000 per year or has $500,000 in net worth, or have a CPA, CFA, MBA, or other master degree. These so called Certified Investors would be allowed to invest in a Reg D private placement alongside Accredited Investors with 2 requirements: must be a sale through a broker dealer and the investment amount could not exceed $50,000 in any one investment.
 
Alan Donenfeld
[redacted]