Comparison guide
Which verification approach satisfies SEC 'reasonable steps' for securities offerings? A side-by-side comparison for compliance teams.
Key takeaways
Show me the regulation
Each panel below is the full structured detail for a regulation referenced in this guide — drawn from the OMINEX regulation registry. Expand any one to see the citation, what it requires in plain language, what fields the examiner reads from the snapshot, the retention period, and the specific OMINEX event types that produce the evidence.
The SEC has stated that relying solely on investor self-certification is not sufficient to meet the 'reasonable steps' requirement under Rule 506(c). Platforms must obtain independent verification or documentation to demonstrate due diligence in verifying accredited investor status.
OMINEX provides provider-neutral verification infrastructure that works with your existing KYC and accreditation providers. You execute, we record, regulators examine.
Rule 506(c) requires issuers to take 'reasonable steps' to verify accredited investor status. The SEC has provided non-exclusive examples of verification methods that satisfy this requirement.
Documents
During SEC examinations, staff will review your verification processes. Be ready to answer the following questions for every investor.
Documents
| Aspect | Third-party vs self-verification |
|---|---|
| Regulatory standing | Third-party verification satisfies SEC 'reasonable steps' requirement; self-attestation alone does not meet 506(c) requirements. |
| Audit-trail quality | Third party: timestamped, independently maintained records. Self-verification: internal records that may be questioned during examination. |
| Conflict of interest | Third party: no financial incentive to approve unqualified investors. Self-verification: platform profits from approving more investors. |
| Provider flexibility | Third party: use any KYC/accreditation provider you prefer. Self-verification: limited to internal capabilities or a single vendor. |
| Implementation cost | Third party: per-verification pricing, no infrastructure overhead. Self-verification: build and maintain compliance infrastructure internally. |
| Regulatory examination | Third party: clear documentation trail for SEC examination. Self-verification: burden of proof falls entirely on the platform. |
| Cross-platform recognition | Third party: attestations can be verified by any protocol. Self-verification: siloed verification not recognized elsewhere. |
From rule to operating fit
The mandate map shows where verification and recordkeeping requirements already apply across digital assets, tokenized capital markets, and related infrastructure. The business case explains how OMINEX helps teams reduce manual proof gathering, answer diligence faster, and move deals forward with less operational drag.
Originally published November 2024 · Last reviewed December 2024
