October 13, 2020

Effective Date for Amended Accredited Investor and Qualified Institutional Buyer Definitions and Order Designating Certain License Holders as Accredited Investors

The amendments to the definitions of “accredited investor” and “qualified institutional buyer” approved by the Securities and Exchange Commission in late August 2020 have been published in the Federal Register. The amendments will be effective on December 8, 2020. The SEC has also published its order finding that persons holding a General Securities Representative license (Series 7), Private Securities Offerings Representative license (Series 82), or Investment Adviser Representative license (Series 65) will qualify as accredited investors under Rule 501(a)(10) under the Securities Act of 1933. We encourage all interested parties to review our client alert for a discussion of the amendments and steps to take now to prepare for the effectiveness of the amended definitions.