Curated by Ken Horenstein
VC Fund 506C
506(c) Fund Launch: Verification & Compliance Essentials
This collection centers on accredited investor verification requirements for Rule 506(c) offerings—the regulatory pathway that permits general solicitation but mandates rigorous investor verification.
Key Insights
Regulatory Framework: Latham & Watkins' interpretive guidance letter reveals that issuers can satisfy "reasonable steps" verification through minimum investment thresholds ($200K for individuals, $1M for entities) combined with written representations—offering a practical bright-line standard beyond document review.
Market Solutions: Multiple verification platforms (Accredd, VerifyInvestor, InvestReady, Opera IQ) provide automated, API-integrated services that:
- Complete verifications in under 12 hours
- Issue 5-year validity letters
- Include KYC/AML compliance
- Maintain 256-bit encryption for sensitive data
Strategic Takeaway: The verification requirement—initially seen as a 506(c) barrier—has spawned a mature service ecosystem that makes compliance straightforward and scalable. The Latham letter suggests regulators may accept investment minimums as verification proxies, potentially simplifying future offerings.
For stakeholders: This represents a clear path to compliant capital raising with established tools and emerging regulatory flexibility around verification methods.