$20k Soon to Be the New Standard Minimum Angel Investment?By http://profile.typepad.com/1237764140s22740 // December 19, 2015 in Accredited Investor Definition, Angels, Emerging Companies, Reg D, Seed Financings
$25,000 is a common minimum investment in startup financings, at least for those conducted offline (not through an accredited crowdfunding platform).
I wonder if that will change, if new SEC staff recommendations for the accredited investor definition are adopted.
The SEC staff recommendations are broad and potentially positive for the startup financing ecosystem: they call for expansion of the means by which an investor may qualify as accredited, which may mean more individuals may eventually be eligible to participate as angels.
However, on preserving the existing financial thresholds for natural persons to qualify as accredited, the recommendations are muddy. Granted, the staff state that the existing thresholds should stay in place; but they also recommend that the current standards should be indexed to inflation, going forward, and that investors be limited in how much they can invest, unless they meet significantly higher financial qualification thresholds.
Here's a quote from the report on the concept for limiting how much the typical angel may invest:
"The Commission could consider leaving the current income and net worth thresholds in the accredited investor definition in place, but limiting investments for individuals who qualify as accredited investors solely based on those thresholds to a percentage of their income or net worth (e.g., 10% of prior year income or 10% of net worth, as applicable, per issuer, in any 12-month period)."
If the investment cap for the majority of angels ends up being 10% per issuer per year, then I'd predict we'll see downward pressure on the $25,000 minimum rule of thumb, and possibly find $20,000 will become a new de facto standard minimum.
I derive that figure from the $200,000 income threshold. Ten percent of that minimum threshold is $20,000. Though if you go with the $1M net worth standard (as refined by Dodd-Frank), you get $10,000.
What will happen is, the issuer will ask the angel, "unless you are super accredited, what is the maximum you can invest, under either the income or net worth tests?" And the investor will say, "none of your business; I meet the standard, that's all you need to know, here's $20k (or $10k) accordingly - don't ask what my income (net worth) is." This reaction hurts startups insofar as it lowers the average investment, but helps in terms of transaction costs insofar as it bypasses (presumably?) any verification requirement that new rules might impose to enforce individual angel investing limits.