An accredited investor is a "rich guy/gal." They have to meet minimum net worth and/or income requirements. You should look up the specifics, but it's generally around $1 million net worth and/or $200,000/year of income. Because they are rich, they are presumed to know what they are doing, and have fewer restrictions on what they can invest in.
$1,000,000 net worth exclusive of primary residence. $200,000 in come for the past two years or $300,000 if filing joint. Also an expectation that income will not decline going forward.
I expect you are getting ahead of yourself and these comments are confusing as they don't apply to you right now. You don't have to be concerned with this yet. It is also not clear to me you need to understand this for SMA. If you do, then your disclosure documents would have a questionnaire that a professional would help you write and it is up to the investor to say if they meet the qualifications. You should consult a professional to confirm your requirements and when they change, what your state expects you to do.
SEC Reg. D. Your compliance department would. If your asking can you get away with skirting it - understand the difference between civil fraud and criminal fraud. I'm not commenting on your requirement to have accredited investors. A lot of that will depend on - as I understand it - your State and products used in their accounts.
Accredited Investors vs. Qualified Clients vs. Qualified Purchasers: Understanding Investor Qualifications https://www.strictlybusinesslawblog...vs-qualified-clients-vs-qualified-purchasers/
Dodd-Frank changed the regs significantly. You really have to check into the regs in your state. The regs vary state to state. https://www.reedsmith.com/en/perspectives/2012/09/new-california-exemption-for-investment-advisers-t Prior Exemption Prior to The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), under section 203(b)(3) of the Investment Adviser Act of 1940, as amended (the “Advisers Act”), any investment adviser who (1) had fewer than 15 clients and (2) who neither held itself out generally to the public as an investment adviser nor acted as an investment adviser to any investment company, was exempted from registration with the Securities and Exchange Commission (“SEC”) (the so-called “Private Adviser Exemption”). Similarly, in California, prior to the Amended Rule, investment advisers that were exempt under section 203(b)(3) of the Advisers Act were exempt from the California investment adviser licensing requirements if they (1) have assets under management of not less than $25 million or (2) exclusively advise “venture capital companies,” as that term is defined in the prior version of section 260.204.9. New Exemption Dodd-Frank eliminated the Private Adviser Exemption and replaced it with two more narrowly defined exemptions for advisers to “private funds,” which is defined in the Advisers Act to mean an issuer that would be an investment company, as defined in section 3 of the Investment Company Act, but for section 3(c)(1) or section 3(c)(7) of the Investment Company Act. Generally, persons who exclusively advise private funds are exempt from registration with the SEC if they (1) exclusively advise “venture capital funds” (the “Venture Capital Fund Exemption”) or (2) manage less than $150 million of assets (the “Private Fund Adviser Exemption”). Advisers relying on either the Venture Capital Fund Exemption or the Private Fund Adviser Exemption are referred to as Exempt Reporting Advisers. Pursuant to the Amended Rule, California adopted an exemption from the California investment adviser licensing requirements that is similar to that of the Venture Capital Fund Exemption and the Private Fund Adviser Fund Exemption (collectively, the “California Exemption”). The California Exemption is only available to “private fund advisers,” which is defined in the Amended Rule4 to mean those advisers who provide advice solely to one or more “qualifying private funds.”5
There are quite a few here. They seem not to want to engage. Try RCM in Chicago. Licensed in all states, but you are going to need to accreditation. Call them and ask.