In a follow-up to a March discussion, the authors look at the details of the recently adopted accredited investor amendments, including some proposed elements that were left out of the final rules.
Moses & Singer partners Allan Grauberd and Howard Fischer discuss the changes the SEC has put in place in its final rules on the definition of "accredited investor," which will go into effect December 8. They look at how the agency expanded what qualifies as accreditation in several ways, including by importing the "knowledgeable employee" framework from the Investment Company Act. After reviewing the treatment of certain entities such as registered advisers and limited liability companies in the new rules, they review some of the pieces of the original proposal that failed to make it into the final rules.
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