What the SEC actually put out

On Sept. 30, 2026, the SEC issued a batch of notices asking for public comment on whether certain credentials should qualify individuals as accredited investors under Rule 501(a)(10) of Regulation D. These are notices, not rule amendments. Nothing changes until the SEC issues an order for a given credential, and it could act on some and not others.

The list, with holder counts as summarized by Morrison Foerster from the SEC releases:

  • A new FINRA accredited investor exam (not yet built)
  • U.S. CPA licenses: about 650,000 holders
  • CFA charters: about 194,000 holders worldwide
  • U.S. CFP certifications: about 110,000 holders
  • Series 79 (investment banking): about 57,000 holders
  • Series 86 and 87 (research analysts): about 5,900 holders

Three licenses are already designated: Series 7, Series 65 and Series 82, under a 2020 order. The wealth tests stay as they are: net worth above $1 million excluding the primary residence, or income above $200,000 ($300,000 jointly) in each of the last two years, per The Industry Spread.

The Federal Register published the CFP notice on Oct. 5, with comments due Dec. 4, 2026. The other notices set comments 60 days after their own Federal Register publication, so check each file number for its date.

The rules every credential must meet

The SEC applies the same test to each one. Under the CFP release, it asks whether the credential comes from an exam by an industry body or accredited institution, whether the exam reliably measures securities and investing knowledge, whether holders can reasonably be expected to have sufficient financial knowledge, and whether the credential is publicly or independently verifiable.

Morrison Foerster notes some common terms across the notices. The credential must be in good standing, holders need not work in the field, and status is personal. A CFP or CPA cannot use it to buy for someone else. Each credential also has to be checkable through a free public source, such as CPAVerify.org, the CFA Institute directory, the CFP Board's search or FINRA BrokerCheck.

The credentials are not trivial to earn. The CFP notice describes a 170-question exam and 6,000 hours of experience (or 4,000 under supervised apprenticeship). The CFA notice describes three exam levels and 4,000 qualified work hours over at least 36 months.

Why issuers should care: verification

For a company raising money under Rule 506(b), accredited status mostly changes who can be in the round. Under Rule 506(c), which permits general solicitation, the issuer must take reasonable steps to verify that every buyer is accredited. That is where the cost sits today.

The SEC's own view is that credential checks should be cheaper. In the Series 79 and 86/87 notice, the staff says those licenses could be easily verified independently, which would likely lower issuers' costs compared with checking income or net worth. It expects the benefit to be greatest in 506(c) offerings. The SEC did not quantify the savings and described the overall effect as potentially modest.

That caution is worth taking seriously. The SEC says it is hard to estimate how many people would newly qualify, because many CFP holders may already meet the income or net worth tests. A broader pool of eligible investors is a possible gain for issuers, but the first gain you are likely to feel is a simpler paper trail.

Where the open questions are

The FINRA exam is the least settled piece. Per the SEC's notice, it would be open to anyone 18 or older, run about 75 multiple-choice questions over roughly two hours at in-person test centers, cost about what the $100 SIE exam does, and stay valid for ten years. FINRA still has to build a way for issuers to verify a pass, including the passage date and the end of its validity period. The SEC is seeking comment on the exam's content, format, fees and validity period. Morrison Foerster stresses that the description reflects FINRA's current plans, not a finished product.

The Industry Spread reports that the exam has no experience prerequisite, which NASAA said it would want, and that Commissioner Peirce questioned whether knowledge goes stale after ten years. It also notes that three commissioners, Atkins, Peirce and Uyeda, supported seeking comment. Investor-protection concerns are the central question the SEC posed for each credential: whether designation could raise issues specific to the people who would newly qualify. The SEC's economic discussion also points to risks of illiquidity and less disclosure than registered offerings.

State law is another wrinkle. Morrison Foerster flags that designations could indirectly affect state securities laws that reference the federal accredited investor definition.

What to do before comments close

This is not a reason to change a live raise. No credential qualifies anyone today. But a few steps make sense for issuers and fund managers planning rounds that will close after any order:

  • Review your investor questionnaire. If orders are issued, subscription documents would need new categories, as Morrison Foerster points out.
  • Decide how you would verify. Confirming a credential is current at the time of sale, rather than at some earlier point, is the safer design, since good standing is a condition.
  • Think about who your investors are. Advisers, accountants and analysts who fall short on income or net worth are the group this would reach. Some issuers may respond with higher minimums or institutional-only offerings.
  • File a comment if you have operating data. The SEC asks about issuer costs and investor-protection effects, and practitioners with real verification experience are the people it is asking.

Comments go to rule-comments@sec.gov with the file number in the subject line (for example File No. 4-934 for the CFP notice) or through the SEC's online form, per the Federal Register notice.

What to watch next

Watch for the remaining Federal Register publication dates, which set each comment deadline, and for whether the SEC acts on the credentials together or one at a time. The FINRA exam is the one to follow most closely: it is the only route open to anyone, and it does not exist yet. This article is general information, not legal advice. Talk to securities counsel before changing how you verify investors.

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