Governance Briefing — SEC modernizes accredited investor definition
The SEC adopted amendments on August 26, 2020 expanding the accredited investor definition to include professional certifications, knowledgeable employees of private funds, and additional entity types, reshaping private offering diligence.
Executive briefing: The accredited investor amendments add knowledge- and credentials-based categories, allow certain fund employees to qualify, and broaden eligible entities, requiring issuers to refresh verification controls for Regulation D offerings.Release Nos. 33-10824; 34-89669 at §§II.A–C
Programme steps
- Update investor onboarding. Incorporate new qualification pathways (Series 7/65/82 licensees, private-fund knowledgeable employees, and additional entity thresholds) into subscription diligence.
- Revise verification records. Adjust reasonable verification procedures to capture credential checks and entity asset tests introduced by the amendments.
- Refresh offering documents. Amend PPMs and risk disclosures to reflect expanded eligibility categories and internal controls for investor qualification.
Sources
- SEC Release Nos. 33-10824; 34-89669 — Accredited Investor and Qualified Institutional Buyer Definitions
- SEC press release on accredited investor modernization
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