Subject: File No. S7-25-19
From: Michael Bernstein, CFA
Affiliation: Sr. Investment Analyst, Galvin, Gaustad Stein

December 19, 2019

I am a Chartered Financial Analyst working as an investment analyst for an RIA in Arizona. Over the course I my career I have performed due diligence on a number of investment vehicles that require investors to be Accredited Investors. The current Accredited Investor definition has prevented me from investing in the products that I perform the due diligence on, alongside the clients that are relying on my analysis. Not only might my ability to invest alongside my clients be reassuring to those clients, but one might also argue that most clients are less qualified than I am to invest in these products based on investment experience and knowledge.

I am happy that this was an initiative that Rep. David Schweikert took up in the House, despite it being applicable to a small number of his constituents, and am very pleased to see this initiative is now receiving the attention of the SEC. I believe certain credentials, certifications and professional experience should qualify someone as an Accredited Investor and would certainly include the CFA Charter in that list of qualifying credentials.