December 30, 2019
Thank you for the opportunity to comment on the proposed amendment to the definition of the Accredited Investor.
I strongly support the expanded definition of accredited investor to include persons with professional certifications, designations and other credentials. However, I believe the initial list of certifications or designations should include certified public accountants (CPAs).
The financial information that accredited investors rely upon to make their financial decisions are governed by generally accepted accounting principals (GAAP). CPAs are the sole designated professional in our society for providing assurance that those financial statements are correct and accurate in all material respects. By definition, CPAs prepare and audit the financial information in private offerings and no other profession is more knowledgeable in understanding that information.
I request that the CPA professional certification is included in the initial list of professional certifications allowing an individual to meet the definition of accredited investor.
Additionally, I would request that an examination be open to all natural individuals to prove their financial sophistication without sponsorship from a FINRA member firm. The testing infrastructure is already in place Series 7, Series 65, Series 82. Any ambitious and astute individual should not be barred from the accredited investor status by lack of association with a FINRA member firm.
Respectfully
Ruthlynn Edwards Black, CPA, CFE