Subject: File No. S7-25-19
From: Raymond Wu, Ph.D.

February 21, 2020

Hi,
I support this change in the definition of accredited investor as it takes into account investors who may be knowledgable yet have not reached the net worth/income targets. Given the proliferation of new types of investments and with lowered minimums I feel this is a prudent adaption. I would only add that if the other FINRA exams (Series 86 87) be also considered as I feel equity research analysts can be considered sophisticated. Given the changes to the FINRA exams for equity research analysts (No longer using the Series 7 but instead now the SIE), I wanted to see if that language could be added directly to the rules to avoid ambiguity.