Subject: File No. S7-25-19
From: Thomas Englis
Affiliation: Associate at Clearvision Ventures

December 19, 2019

Hi,

Thank you for opening up the commenting period. I am in favor of expanding the definition of 'accredited Investor' to include individuals who are knowledgeable of private markets but do not have the capital required under the existing definitions. I am a perfect example of why the existing rules are not reflective of sophistication and understanding of risk.

Having worked in the venture capital industry for 4 years, I have a very high level of knowledge of technology startups. However, as I am early in my career, my income is not high enough to meet the accredited investor threshold. The existing law does not accurately measure an individual's knowledge of risk. If the definition was changed to include individuals who work in the private markets, I believe it would be greatly beneficial to the overall startup and innovation ecosystem. In addition I believe this would be a positive first step on the road to making private markets more accessible, beyond high net worth individuals.

Best,
Thomas Englis