SEC proposes CFP certification as accredited-investor qualification
The proposal would affect CFP holders in good standing, with comments due by Dec. 4 2026
The Securities and Exchange Commission released a notice on Oct. 5 2026 proposing to designate holding a Certified Financial Planner (CFP) certification in good standing as a qualifying natural-person criterion for accredited-investor status under Rule 501(a)(10). The proposal is identified as Release No. 33-11448, File No. 4-934, and invites public comment.
Comments must be submitted on or before Dec. 4 2026. The Commission accepts electronic comments through its internet form or email, and paper comments to Vanessa A. Countryman, Secretary, at the SEC's Washington address. All submissions should reference File Number 4-934, and the Commission will post comments on its website while redacting any obscene or copyrighted material.
The notice recalls that Regulation D provides exemptions for securities offerings and that the accredited-investor definition is intended to capture persons whose financial sophistication makes registration unnecessary. Current natural-person categories include net-worth thresholds of $1,000,000 (excluding primary residence), income thresholds of $200,000 (or $300,000 jointly) for the two most recent years, and holdings of professional certifications already designated by the Commission. The CFP designation is not presently listed, prompting this request for comment.
The SEC's background section cites that approximately $400 billion was raised in Regulation D offerings (excluding pooled funds) between July 1 2024 and June 30 2025. It also references other thresholds - such as $10 million for Rule 504 offerings, a limit of 35 non-accredited investors for Rule 506(b), and $5 million asset thresholds for certain employee-benefit plans - to illustrate the regulatory context in which the CFP designation would operate.
Stakeholders, including CFP professionals, issuers, and investor advocacy groups, are encouraged to submit their views on whether the CFP credential should be added to the list of designations that confer accredited-investor status.
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