Accredited Investor Definition Regulation - Comment Letter - Real Estate Investment Securities Association - March 11, 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 11, 2011

In the comment letter, REISA recommends:

  • "excluding both the value of the primary residence as well as all indebtedness secured by the primary residence from the calculation of net worth or, in the alternative, excluding any debt that is non-recourse to the investor or his assets from the calculation of net worth regardless of whether such nonrecourse debt is less than, equal to or in excess of the value of an investor’s primary residence; and
  • including a grandfathering or transition provision for existing investments to allow investors, who previously qualified as accredited investors, to be able to continue to be treated as accredited investors so as to allow them to protect their current investments and investment positions."


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