April 15, 2020
Thankyou for making this proposal and being open to comments. I am in support of the proposed amendment to add new categories of natural persons that may qualify as accredited investors. Specifically - please allow anyone who passes a suitable test to gain accreditation.
I consider the current accredited investor rules to be un-american in spirit. Everyone I have spoken to on this matter are honestly skeptical of it'strue purpose being to protect investors as there's nothing to stop people making terrible gambling decisions in Las Vegas or spending a lot of money that they can't afford on the lottery. Both of these have terrible odds of success - and yet a single person with no debt and no dependents making - let's say for arguments sake - $190k a year - is prevented from taking part in the best investment opportunities with far better odds? How is someone in that position unable to weather some investment risk? Why are they relegated to the scraps of the investment world? The fact is - the best early investment deals (which of course are the ones with the best returns) tend to go to accredited investors in the US.
Please bear in mind that the current accredited investor credentials do nothing to ensure that the investor is either educated or can withstand the risk of their investments going bad. It many ways though - it does reward those already born into a life of privilege while simultaneously handicapping those that are making their own way - and this is what I consider tobe un-American in spirit.
The average American is being put at a huge investment disadvantage compared to the rest of the world - and it goes against what I believe America stands for - freedom and opportunity. By preventing people from making their own investment choices - most people of this country are being forced to miss out on some excellent high risk high reward opportunities that have the potential to move theneedle on their personal wealth with a suitable risk mitigation strategy.
Mandate classes if you want investors to be educated. Make them pass a test to make sure they are suitably aware of risk management etc. Just allow them to participate as a free country should.