Subject: S7-25-19 - Comment on amending the 'Accredited Investor' definition
From: Brian Schreiner
Affiliation: CMG Capital Management Group, Inc.

February 20, 2020

I’m glad you’re addressing the current accredited investor definition, which is obviously discriminatory and outdated, but the proposed rule does not go far enough.  It should further expand access to private investments.

As an investment advisor representative with over 20 years of experience, I have had the opportunity to represent many accredited and non-accredited investors.  This has led me to an inescapable conclusion. The current standard has almost NO bearing on an individual’s sophistication level, or her/his ability to assess risk.  If it is the intent of the SEC to expand capital creation, provide greater access to private investments and eliminate the obvious discriminatory practice of rulemaking based on financial status, the proposed rule has missed the mark.  A comprehensive solution that could meet those goals would be to define any registered investment advisor with a fiduciary duty to manage assets on a discretionary basis, as an accredited investor for those clients.  We (the advisors) already have a statutorily imposed requirement to make investment decisions in our clients’ best interests. In addition, we are well prepared to make recommendations that are best suited for an individual client.  Thank you.


Brian Schreiner
Senior VP, Private Wealth Group
CMG Capital Management Group, Inc.
10 Valley Stream Parkway, Suite 202
Malvern, PA 19355