Subject: Amending the "Accredited Investor" Definition
From: Billy Stern, Managing Partner
Affiliation: Stern Brothers Asset Management, LLC

Feb. 18, 2020

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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.
Billy Stern 
Managing Partner 
Stern Brothers Asset Management, LLC 
Cell: (214) 738-4252 

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