Subject: File No. S7-08-19
From: Steven Marshall
Affiliation: Director of Finance and IS

August 18, 2019

Being an accredited investor has nothing to do with annual income or net worth. It has everything to do with education and experience along with acknowledging the risks involved at the juncture of making the investment. There are so many supportive reasons to acknowledge education and experience over net worth and income that this entire notion for an accredited investor based on just income or net worth is unfathomable. One example is just inheriting wealth vs being an entrepreneur with higher education like an MBA and decades of experience protecting and investing capital but just not at the watermark of net worth or income as the current accredited status. Yet much of the inherited wealth is squandered upon all consumer oriented gimmicks. Moreoever, the financial markets allow uninformed people to buy options or futures or equities without any idea who is managing the paper or investment. The accredited investor designatino needs to show experience and education for determining credentials.