Accredited Investor Definition Regulation - Comment Letter - American Bar Association - March 31, 2011

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Dodd-Frank Timeline,
Net Worth Standard for Accredited Investors, SEC
Proposal Date Final Rule Issue Effective Date
January 31, 2011 December 29, 2011 February 27, 2012

Net Worth Standard for Accredited Investors
March 31, 2011

In the letter, the ABA's comments fall under the following categories:

  • proposed language for the net worth standard for accredited investors;
  • other definitional issues related to the accredited investor net worth standard, such as "primary residence" and "proceeds of debt secured by primary residence incurred to invest in securities;"
  • timing considerations; and
  • transition considerations.

Although the ABA supports the SEC's provision to exclude the "primary residence of a natural person" as a factor in determining the net worth standard, it is suggested in the comment letter that final rule language be changed to clarify the accredited investor test. The ABA believes that any other proposed changes concerning accredited investors are not necessary at this time.


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