December 21, 2019
The changes to Reg D don't go far enough. Everybody who manages their own portfolio, however small it may be, is sophisticated enough to understand the risks and should be able to participate in the best private offers. The measure of sophistication has to be not the income, but financial experience (either professional or personal), and at least everybody who has an investment or pension account and trades their own book (through Fidelity, Schwab, Robin Hood, etc,) has sufficient understanding of financial markets. Freezing them out of the best private deals actually increase the risk as they are forced to seek out substandard deals. Portals like AngelList has been around for a long time and have a proven track record, that shows their vetting process and due diligence are quite thorough, with respect to the projects they list, and consumers have sufficient protection when they invest through these portals. While I understand the SEC's desire to protect individual consumers, restricting access to high income / net worth individuals has the opposite effect. In today's world there are many people who don't earn much but are nevertheless much more financially savvy than most high earners.