One Down, One To Go: The SEC Completes The First Required Dodd-Frank Act Regulation D Rulemaking

The Securities and Exchange Commission (the "SEC") recently completed the first of two Regulation D rulemakings mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd- Frank Act"). The Dodd-Frank Act modified the net worth standard included in the definition of "accredited investor" under the Securities Act, as well as directed the SEC to adopt amendments disqualifying the offer or sale of securities in Rule 506 offerings by certain felons and similarly situated bad actors. In December 2011, the SEC adopted amendments to the net worth standard, with those changes effective on February 27, 2012.¹ Meanwhile, the agency now expects to adopt amendments providing for disqualifications with respect to felons and bad actors in the first half of 2012.²