Subject: Update Accredited Investor Definition
From: Kevin Gebert, Investment Analyst
Affiliation: Holualoa Companies

Mar. 4, 2020

I want to urge you to expand the definition of an accredited investor to include a category for investment certifications and designations.  Personally, I have an undergraduate and masters degree in Finance, have earned my CFA Charter, and have worked for a real estate investment firm and family office for eight years making private investments.  In spite of all of that, under the current rules, I am not considered sophisticated enough to make my own private investments merely because I don’t make enough money and have not yet built up enough assets.
My wife and I nearly qualify on the income basis.  She is a high school  teacher, though had she chosen a more lucrative profession we would almost certainly qualify even under the current rules.  The current narrow definition limits opportunities for people in similar economic situations.  That limits our ability to diversify our investments, build wealth, and help seed innovation and growth in our community.
Please consider expanding the accredited investor definition to allow greater equality of opportunity to more investors.
Holualoa Companies
Kevin Gebert, CFA
Investment Analyst
O: [redacted] | C: [redacted]
3573 E Sunrise Dr., Suite 225, Tucson, AZ 85718