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Comments on SEC Concept Release on Harmonization of Securities Offering Exemptions

The IAA recommended amending the definition of “accredited investor” and “qualified institutional buyer” or “QIB,” clarifying that certain communications do not violate the “general solicitation” or “general advertising” prohibitions, and expanding the ability of investors to invest in closed-end funds that invest in privately offered alternative investments.

October 18, 2019

Keywords: Accredited Investor, Private Offerings, QIB

Categories & Topics: Compliance, Private Funds

Comments on SEC Amendments to the Definitions of “Accredited Investor” and “QIB”

The IAA supported expanding the definition of “accredited investor,” but recommended that the SEC consider alternative methods of showing investor sophistication, including discretionary account clients of SEC-registered investment advisers. The IAA also recommended expanding QIB eligibility for 144A offerings.

March 18, 2020

Keywords: Accredited Investor, QIB

Categories & Topics: Compliance, Private Funds

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