In a comment letter to the FDIC on Monday, the American Bankers Association offered support for the Securities and Exchange Commission’s proposal to amend the definition of “accredited investor” under Regulation D and “qualified institutional buyer” definition under Rule 144A. The proposal is intended “to identify more effectively institutional and individual investors that have the knowledge and expertise to participate in our private capital markets and therefore do not need the additional protections of registration under the Securities Act of 1933.”
Specifically, ABA supported the addition of “institutional accredited investor” to the QIB definition in Rule 144A, expanding the number of collective investment funds in that definition. The association also urged the SEC to consider expanding the “family of funds” test to bank-maintained collective investment funds; asked the SEC to expand the scope of Rule 180 to include a safe harbor for multiple employer plans; and urged the SEC to include the ABA designation of CTFA as a qualifying for accredited investor status for natural persons.
