SEC Proposes to Update the Definition of "Accredited Investor"

By Steve Quinlivan, Bryan Pitko and Jaclyn Schroeder

Stinson has prepared an analysis of the SEC's proposed amendments to the definition of “accredited investor” to add new categories of qualifying natural persons and entities, and to make certain other modifications to the existing definition. Specifically, the proposed amendments would:

  • Add new categories of natural persons that may qualify as accredited investors based on certain professional certifications or designations or other credentials or their status as a private fund’s “knowledgeable employee”
  • Expand the list of entities that may qualify as accredited investors and allow entities meeting an investments test to qualify
  • Add family offices with at least $5 million in assets under management and their family clients
  • Add the term “spousal equivalent” to the definition

For more information on the proposed amendments, please contact Steve Quinlivan, Bryan Pitko, Jaclyn Schroeder, Jack Bowling, Scott Gootee or the Stinson LLP contact with whom your regularly work.

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