College Savings Plan Network Tuition Programs Qualify as AIs or QIBs

The SEC Division of Corporation Finance asserted that although a tuition program established by members of the College Savings Plan Network ("CSPN") is not necessarily organized as an entity specifically listed in Securities Act Rule 501(a)(3) of Regulation D or Rule 144A(a)(1)(i)(H), the program may be treated as an "accredited investor" ("AI") and "qualified institutional buyer" ("QIB") as defined in each rule, respectively, provided that it meets the substantive requirements of each rule. The SEC interpretation was in response to a request made "as to the status of the prepaid tuition programs established by members of CSPN (the “tuition programs”)".