January 9, 2020
Dear SEC,
This is concerning comments to File No. S7-25-19 - proposed amendments to the "accredited investor" test.
By way of background, I am a corporate and tax attorney. I work with many high net worth individuals and entrepreneurs in Silicon Valley, and I also see many smart people who do not currently qualify for the "accredited investor" rule as it stands now.
I strongly support the proposed changes in the attachment, as I have seen first hand, people in Silicon Valley worth $13 million dollars that do not know anything about investing, while simultaneously seeing a very good many educated, up and coming individuals worth less than $1 million who know far more than those with substantial assets and income that "should" qualify.
This problem is particularly pronounced in the San Francisco Bay Area, where couples routinely make $500,000 joint taxable income, and people are worth more than $1 million, yet know very little about finances and investing.
Moreover, I think these changes are long overdue, as they should have been implemented 5, 10, or 15 years ago.
I sincerely hope that these rules pass.
Regards,
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C. Alex Naegele, A Professional Law Corporation
19925 Stevens Creek Blvd, Suite 100 | Cupertino, CA, 95014