Feb. 18, 2020
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
February 18, 2020
Vanessa A. Countryman, Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: Amending the “Accredited Investor” Definition / File No. S7-25-19
Dear Ms. Countryman,
It is with great appreciation that the Securities and Exchange Commission is considering amendments to the definition of an “accredited investor” and is open to comments from the investment community. My comments are brief, but I hope they will be taken into consideration since I have had two decades of experience in the area of investment products.
The barriers to entrepreneurs to get excellent investment opportunities to the public are expensive, frustrating, opaque and lack the ability to scale small projects forward. I have experienced this firsthand with a tokenization investment project. I have never understood the rationale of a “sophisticated” investor because they have a high net worth or certain income levels. If your income drops, then suddenly you are not a sophisticated investor anymore?
My recommendation would be to allow further investor protection by providing more reliance upon the fiduciary role of financial advisors and wealth managers. One way to accomplish this would be to not only allow advisors with credentials to be accredited investors themselves, but also to an unlimited amount of investors that they represent.
Again, thank you for the opportunity to comment and I hope that modernization of the accredited investor rules will be attained.
Best,
Billy Stern
Managing Partner
Stern Brothers Asset Management, LLC
WStern@SternWealthAdvisors.com
Cell: (214) 738-4252
www.SternWealthAdvisors.com
This electronic message transmission contains information from Stern Brothers Asset Management, LLC which may be confidential or privileged. The information is intended for the use of the individual or entity whose electronic mail address is named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us immediately.