January 2, 2020
I am thrilled this antiquated law is being reviewed to allow greater access to our private capital markets. The definition, as it currently stands, is inherently biased precluding non-millionaires from participating in the most lucrative opportunities available in the marketplace. Certainly anyone capable of passing a Series 7, etc. securities examination is able to assess the risk of private placements appropriately.
The only problem with the proposed changes is they don’t go nearly far enough in providing an equal playing field. 506(c) offering should also be open to “sophisticated investors” as the rule now stands under 506(b) offerings.
Rick Courtney
President - Brass Multifamily