Feb. 23, 2020
Ms. Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F. Street N.E. Washington DC 20549-1090 Dear Ms. Countryman: I am currently a 3rd-year law student, with an anticipated graduation date of May 2020. I am writing in support of amending the "Accredited Investor" Definition. The rule is arbitrary because it assumes investors with a net worth of $1 million or an annual income of $200,000 ($300,000 for couples), are sophisticated enough to invest in the private market. This is not true. Throughout my years as a student, I have gained immense knowledge and experience about capital (private) markets. My experience and education should not be discredited because I do not have a net worth of $1 million or annual income of $200,000. My education should not be discredited because I have had to explain the pros and cons of private investments to multiple individuals who are considered "accredited investors." According to the SEC's rationale for this rule, accredited investors should be more knowledgeable about private investment opportunities than me, which does not seem to be the case at times. If the SEC feels that financial sophistication is not a good gauge to access private investments, then I hope that the SEC will allow individuals with advanced degrees to invest in the private market. I am in support of the SEC's rule change because I am being restricted as a "non-accredited investor" from accessing the private market. I am a voracious reader of the Wall Street Journal, New York Times, Yahoo! Finance and Bloomberg News, so constantly being inundated with the success stories of these unicorn companies that have conducted IPOs is angering me. I am missing out on opportunities and being relegated to publicly traded companies as my investment option for wealth generation. In fact, I think that the arbitrary "accredited investor" definition may have played a role in the wealth inequality that we are experiencing today. (I am aware that the factors which have engendered wealth inequality are complex and too robust for a discussion on this platform.) I stand in support of this new policy proposal. Best, Cody