March 4, 2019
In the current ruling, testing the waters (a.k.a. Solicitation of Interest) is only allowed for accredited investors. Accredited investors are a limited group with many different options for investing than the broader public. To be cost effective, and have full market interest, this ruling should be expanded beyond this small group of accredited investors. The current ruling would be parallel to testing a filtered glass of water vs. testing the ocean. This rule would not adequately represent the opinions of the full market and effectively be discriminating against the opinions of a broad swatch of the population that has less than $1M in assets or salary history of anything less than $200K. The rule claims to be evaluating the markets interest but attempts to do so by only polling a thin subset of the broader market. We believe it needs to be amended.