Letter to Mary Jo White, Chairwomen of the US Securities and Exchange Commission - Expanded Access to Startup Business Investing Opportunities

Letter

The Honorable Mary Jo White, Chairwoman
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Dear Chairwoman White,

As the United States Securities and Exchange Commission (Commission) conducts its review of the definition of an individual accredited investor, we strongly urge you to adopt an additional accreditation standard that takes into account other relevant factors besides financial metrics to determine financial sophistication. Specifically we request that you consider the quality of an individual's experience and knowledge.

Under the Commission's current rules, many individual investors who do not meet the income or net worth thresholds, are equally or more financially sophisticated as those who do meet the current standards. In our view, those individuals with significant professional experience and knowledge should also be able to qualify as an accredited investor, based on the Commission's definition of sophistication: those "having sufficient knowledge and experience in financial and business matters to make them capable of evaluating the merits and risk of the prospective investment." As such, we strongly urge you to adopt an additional accreditation standard based on an individual's professional experience and knowledge. This standard could include, but should not be limited to, individuals who meet one of the following criteria: a) previous or current investors in an exempt offering under Regulation D; b) an advanced degree in business or finance or a chartered financial analyst credential or similar designation; c) work experience currently or formerly as a c-level executive at a company which, during the time of such employment, has sold shares or debt; or d) successful passage of the broker-dealer registration exam.

We are hopeful that the Commission will consider adopting an additional standard to the accredited investor definition based on an individual's experience and knowledge. This additional standard will allow more sophisticated individuals to provide greater investment capital and contribute to the growth and expansion of startups and small businesses and our economy as a whole.

Sincerely,

Jared Polis Bradley Schneider

Ron Kind Derek Kilmer

John Delaney David Scott

Cedric Richmond Scott Peters

Juan Vargas Bill Owens

Tony Cardenas John Carney

Susan DelBene Mike Quigley

Gerry Connolly