SEC Advisory Committee On Small And Emerging Companies Issues Further Recommendations On Accredited Investor Definition

On July 19, 2016, the SEC Advisory Committee on Small and Emerging Companies (the “Advisory Committee”) met and drafted its recommendations and response to the SEC report on the definition of accredited investor.  The subject of changes to the definition of accredited investor has been debated in a series of reports, recommendations, proposals and comment letters since early 2015.

On December 18, 2015, the SEC issued a 118-page report on the definition of “accredited investor” (the “report”).  The report follows the March 2015 SEC Advisory Committee recommendations related to the definition.  The SEC is reviewing the definition of “accredited investor” as directed by the Dodd-Frank Act, which requires that the SEC review the definition as relates to “natural persons” every four years to determine if it should be modified or adjusted.  See my blog HERE on the report and additional background on the subject.

At the July 19 meeting, the Advisory Committee finalized a draft of a letter