Feb. 18, 2020
To Whom it May Concern, I just wanted to share a quick note on the proposal Amending the “Accredited Investor” Definition as an employee who is unable to participate in what I viewed, and still view, as the #1 benefit offered to me upon joining a small investment firm – the ability to invest in the fund I joined with no management fee. I spend all day every day evaluating investments on behalf of others, and am prohibited from investing my own money in the top ideas that make it into the fund (as well as being severely limited in other investments). Because of the rules around accredited investors, taking this job has largely precluded me from participating in the equity markets, despite the fact that I have dedicated my working career to becoming an expert in the space. Limiting knowledgeable individuals’ ability to participate in the equity markets is not the goal of the SEC, but in this case it is an unintended consequence of a policy designed to protect innocents who do have full understanding of the risks or the means to stomach the potential consequences – a group that should be distinguished from licensed employees. I understand that it is a small group of individuals who are affected in this way, but wanted to share my thoughts as it is a slightly different angle which I believe should be considered. I believe that a public equity employee should be able to co-invest in its company funds the same way a private equity employee can. This is a real and very important benefit that the SEC should certainly allow. I commend you for initiating that process, and sincerely hope that the knowledgeable employee change is made. Best, Tyler Page