Just before 2011 year-end, the SEC adopted final rules first proposed in January 2011 to exclude the value of an investor's home when determining if an investor meets the net worth test for an accredited investor. A person's status as an accredited investor affects eligibility, sophistication and information requirements for certain unregistered securities offerings. The final rules differ from the proposed rules by addressing home equity indebtedness incurred in the 60 days prior to an offering, and by grandfathering securities purchase rights held prior to enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank").
This post updates earlier posts entitled "Legal Update: Dodd-Frank Redefines 'Accredited Investor'" posted on July 23, 2010, "Legal Update: Dodd-Frank Redefines 'Accredited Investor'" and the SEC Provides New Guidance" posted on September 3, 2010, and "SEC Proposes Amendments To Reflect Dodd-Frank's Definition Of Accredited Investor" posted on February 7, 2011.
Please see full publication below for more information.