December 18, 2019
I believe that expanding the definition of an accredited investor beyond the basic income and net worth tests is long overdue. In my opinion this actually served as a barrier to entry for smaller investors and a protection for large, already wealthy investors.
Considering the types of expansion, I feel that the Series 7 and Series 65 are a great starting point. I also believe that a licensed CPA should be included. CPA certifications are not only issued through a rigorous examination process and require extensive education, they are also licensed by state regulatory bodies and are under more oversight than many other types of certifications. Overall, I believe that any certification which also requires licensing through a government body is a stronger basis. Licensure by a governing body not only sets in place strict requirements for issuing the license and maintaining certification, it also creates a duty to the public at large.
I do not generally support allowing accredited investor status based solely on education as there is not enough uniformity in educational quality.
Thank you very much for your time and the opportunity to comment.