Calling the current standards “feeble” and “in desperate need of modernization,” NASAA said the thresholds should be raised significantly, modified to exclude agricultural and retirement assets and indexed to inflation to continue serving the interests of retail investor protection. “The SEC has considered implementing many of these changes in the past; it is high time the commission did so,” Gerold wrote.
Although NASAA disagrees with the proposal’s proposed treatment of certain investors, NASAA does not object to expanding accredited investor status as to investment advisory firms (whether SEC registered or state registered), rural business investment companies, nonprofit limited liability companies and family offices.
Before any final rulemaking, Gerold suggested that the SEC should gather data on private offerings to individual investors “to better understand the types of companies and investors that reasonably should be dealing with one another,” NASAA said in a statement.