January 6, 2015
Our firm serves as a placement agent to alternative investment firms and the funds they manage. We almost exclusively refer institutional investors to those firms/funds. However, under various scenarios accredited individuals working at those institutions or other closely affiliated individuals (friends and family) also desire to invest. These sophisticated, accredited individuals make up less than 5% of assets placed through our firm (likely less than 1% most of the time).
I respectfully request a de minimis and/or knowledgeable employee exemption to allow for these one-off capital raises without violating the proposed CAB rules. Such an exemption would certainly remain within the spirit of the proposed rules.
Respectfully,
Arne Rovell
Coronado Investments, LLC