The Institute strongly urges the Commission to adjust the dollar thresholds to correct for this erosion. Section 413 of the Dodd-Frank Wall Street Reform and Consumer Protection Act required the Commission to exclude the value of private residences from the net worth calculations in the definition of “accredited investor,” which it did in 2011. That is certainly a positive first step towards modernizing the accredited investor definition, but much more needs to be done to respond to the concern that inflation and growth in wealth has inappropriately made a substantial number of investors eligible to invest in private.
