February 15, 2020
Our firm, Inportal, is primarily involved in private placements and in particular in digital tokenized securities, so we are acutely aware of how the current accredited investor regulations exclude many people from the entire alternative asset class of investments just because they dont have the requisite salary or accumulated wealth. Hearing that The Securities and Exchange Commission has proposed amendments to the definition of accredited investor, I am pleased to submit the following two comments.
The proposed amendments propose expanding the criteria of accredited investors based on their professional knowledge, experience, or certifications such as being a CPA, and designations, such as a Series 7, 65 or 82 license, or other credentials issued by an accredited educational institution. At Inportal we endorse this proposal and would point out that the Series 65, known as the Uniform Investment Adviser Law Examination is especially useful for accreditation because it is designed to qualify individuals to provide investing and general financial advice to clients as an Investment Advisor Representative, and most importantly, the Series 65 exam does not require an individual to be sponsored by a FINRA member firm.
Our second comment proposes maintaining a public database of accredited investors similar to the list maintained by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury which is regularly used in the KYC process. With the advent of digital securities and the tokenization of private equity securities being traded on exchanges, having a machine-readable record of accredited investors would greatly enhance the functioning of these new capital markets in conducting KYC and accreditation checks for Reg D transactions.
We look forward to the Commissions final decision on amendments and this opportunity for comment.
Stephen Inglis CFA
Chief Executive Officer