The Securities and Exchange Commission (the “SEC”) recently proposed amendments (the “Proposed Amendments”) to the Securities Act of 1933 to reflect the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) relative to the definition of “accredited investor” under Rule 501 of Regulation D. The Proposed Amendments seek to codify Section 413(a) of the Dodd-Frank Act, which required the definition of “accredited investor” to exclude the value of a person’s primary residence for purposes of determining whether such person qualifies as an “accredited investor” under the $1 million net worth test.

Under the Proposed Rules, the accredited investor net worth standard for natural persons would be as follows...