December 21, 2019
I encourage this expansion of the accredited investor definition. One years income does not indicate whether an investor is savvy or not. Professional experience, credentials and education are better indicators of whether an investor is sophisticated enough to evaluate a private investment, not just a level of income. This new definition is therefore a step in the right direction. Adding CPA credentials seems appropriate as well. Investors should be able to take a test (such as the Series 65 as this new rule includes) to demonstrate their sophistication. Furthermore people who were accredited investors in years past do not immediately become less sophisticated in a year when their income dips below the threshold. Once accredited an investor should continue to be so going forward. People early in their investment career or who are highly educated but do not come from a wealthy background should be given an opportunity to build wealth through private investments. Thank you for initiating this expansion of the accredited investor definition.