This is old news and the market has already responded. The vast majority of funds still aren't going to generally advertise. Turn on the TV or radio and every once in a while you'll hear an ad that says, "accredited investors only" at the end of it. But they are rare.
Baron is mostly correct. It doesn't just apply to leads developed from advertising. Funds now have a choice, to advertise publicly or not. Choosing to advertise means that all investors must be subjected to a more thorough verification process regardless of how the lead was generated. They aren't going to let funds claim that certain leads were not generated through general solicitation and are thus not subject to the new verification rules. This typically means that a manager will need to gather W2s, tax returns, bank statements, etc. to verify the accredited status of the investor.
Most funds view this as a huge hassle, as do most investors. Imagine sitting in a meeting with a guy worth $10MM who has met with many other managers before, so he knows the process. But suddenly you are the only oddball demanding his tax returns and bank statements before he can invest.
Fortunately for most of us, when they implemented 506(c) they also left 506(b) intact, which allows the vast majority of funds to just go on with business as usual.
, but if any clients develop from those leads, the fund must still ensure that those clients meet the minimum qualifications for investing on that level before moving forward.