On October 5, 2026, the SEC asked for comment on designating three new credentials as qualifying individuals for accredited investor status: passing a FINRA-developed accredited investor exam, holding a CFA charter, or holding CFP certification. They are notices, not final orders, and comments are due December 4, 2026. Until the SEC acts, issuers should keep qualifying investors under today's income, net-worth, and Series 7/65/82 tests.
Key takeaways
- Three SEC notices (Releases 33-11445, 33-11447, 33-11448) consider adding a FINRA exam, the CFA charter, and CFP certification as accredited investor pathways.
- Nothing has changed yet: the comment period runs to December 4, 2026, and the SEC must issue an order before any new pathway applies.
- Series 7, 65, and 82 license holders in good standing already qualify under an order issued in 2020.
- A larger accredited pool matters most for Rule 506(c) raises, where every purchaser must be accredited and verified.
What the SEC published
In three notices published in the Federal Register on October 5, 2026, the Securities and Exchange Commission said it is considering orders that would let individuals qualify as accredited investors by passing an accredited investor exam to be developed by FINRA [1], by holding a Chartered Financial Analyst charter in good standing [2], or by holding Certified Financial Planner certification in good standing [3]. Each notice requests public comment by December 4, 2026 [1][2][3].
These are notices of a potential order and requests for comment — not final rules. No new pathway is available to issuers or investors until the Commission actually issues a designation order.
Why the definition matters to issuers
The accredited investor definition in Rule 501(a) is the gatekeeper for most private capital in the United States. The SEC calls it a cornerstone of Regulation D [3], and the Commission's small-business advocate reports that roughly $400 billion was raised in Regulation D offerings, excluding pooled funds, between July 1, 2024 and June 30, 2025 [4].
Today, an individual generally qualifies through wealth or income — net worth above $1 million excluding a primary residence, or income above $200,000 ($300,000 jointly) in each of the last two years with the same expected this year — or through a professional credential the SEC has designated under Rule 501(a)(10) [1]. When it created that credential pathway in 2020, the Commission designated the Series 7, Series 82, and Series 65 licenses [1].
What would change for a private raise
The practical effect would be a larger pool of individuals an issuer can accept — and, in a Rule 506(c) offering, publicly market to. Rule 506(c) permits general solicitation only if every purchaser is accredited and the issuer takes reasonable steps to verify that status [5]. Credential-based status is, in principle, simpler to confirm than income or net worth, which typically means reviewing tax forms, brokerage statements, or third-party letters [5].
For Rule 506(b) offerings — no general solicitation, and up to 35 non-accredited purchasers who must receive specified disclosure — the change would mostly reduce how often an issuer needs to prepare that additional disclosure [6].
What to do now
Keep investor questionnaires and verification procedures on the current definition. Do not treat a CFA charterholder, CFP professional, or exam-taker as accredited on that basis alone unless and until an order is issued. Issuers and funds that would benefit — particularly those raising from financial professionals — can submit comments through the SEC's site before December 4, 2026.
Frequently asked questions
- Can a CFA charterholder invest as an accredited investor today?
- Only if they otherwise qualify — for example through income, net worth, or a Series 7, 65, or 82 license in good standing. The CFA pathway is under consideration in SEC Release 33-11447 and is not yet in effect.
- When could the new pathways take effect?
- Not before the SEC reviews comments, which are due December 4, 2026, and then issues a designation order. The notices do not set an effective date.
- Does this change Rule 506(c) verification?
- Not yet. Issuers must still take reasonable steps to verify accredited status under the existing definition.
Sources
- [1]U.S. Securities and Exchange Commission, “Potential Designation of Passage of an Accredited Investor Exam to Be Developed by FINRA as Qualifying Natural Persons for Accredited Investor Status (Release No. 33-11445),” October 5, 2026.
- [2]U.S. Securities and Exchange Commission, “Potential Designation of Chartered Financial Analyst Designation as Qualifying Natural Persons for Accredited Investor Status (Release No. 33-11447),” October 5, 2026.
- [3]U.S. Securities and Exchange Commission, “Potential Designation of Certified Financial Planner Certification as Qualifying Natural Persons for Accredited Investor Status (Release No. 33-11448),” October 5, 2026.
- [4]U.S. Securities and Exchange Commission, “Office of the Advocate for Small Business Capital Formation, Fiscal Year 2025 Annual Report,” January 8, 2026.
- [5]U.S. Securities and Exchange Commission, “General Solicitation — Rule 506(c),” Accessed November 2026.
- [6]U.S. Securities and Exchange Commission, “Private Placements — Rule 506(b),” Accessed November 2026.
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This article is for informational purposes only and is not legal, tax, or investment advice, or an offer to sell or a solicitation of an offer to buy any security. Regulatory proposals described here may change before adoption. Securities offered through Umergence LLC, Member FINRA/SIPC.
