Accredited Investor Standard SEC Comment Letter

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Comment Letter from Securities Regulation Committee of the New York State Bar Association to the Securities and Exchange Commission. The comment letter addressed a proposed set of rules that would impact the accredited investor qualifications for participating in 3(c)(1) pools, by among other things, imposing a new accredited investor classification for natural persons - a requirement of $2.5 million of investments in addition to Regulation D net worth requirements, which are also to be increased. The new rules contain a carve out for venture capital funds, but will affect private equity and hedge funds which utilize the 3(c)(1) structure.

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