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Commentary by Steven Lofchie

The SEC Divisions of Corporation Finance and Economic and Risk Analysis analyzed various approaches for modifying the definition of an "accredited investor." Under the Dodd-Frank Act, the SEC must review this definition as it applies to natural persons every four years. The Divisions' recommendations for methods to revise the definition included: The SEC should revise the financial thresholds requirements and the list-based approach for entities as follows: leave the current income and net worth thresholds in place, subject to investment limitations; add new inflation-adjusted income and net

The FDIC reminded banks and other supervised institutions of its new rule on filing requirements and processing procedures in connection with changes in control. The new rule goes into effect on January 1, 2016. The rule consolidates and conforms the regulations of state nonmember banks, state savings associations and certain parent companies, and is intended to make existing FDIC practices more transparent. The rule adopts definitions for previously undefined terms, such as "Acting in Concert," "Convertible Securities" and "Voting Securities." Under the rule, the acquisition of convertible