SEC seeks comment on FINRA exam as accredited investor qualification

The Securities and Exchange Commission issued Release No. 33-11445, File No. 4-931, announcing that it is evaluating whether to designate passage of an accredited investor exam, to be developed by the Financial Industry Regulatory Authority, Inc. (FINRA), as a qualifying criterion for natural persons seeking accredited investor status under Regulation D.

The notice, published in the Federal Register on October 5 2026, solicits public comment through December 4 2026. Comments may be submitted electronically via the Commission's internet comment form or email, or in paper form sent in triplicate to the Commission's Secretary. All submissions must reference file number 4-931, and the Commission will post the comments on its website, subject to redaction of obscene material or copyrighted content.

The proposed exam would function as a professional certification or designation, similar to the existing qualification under Rule 501(a)(10) that permits individuals who hold designated certifications from accredited educational institutions to qualify as accredited investors. The Commission's background discussion reiterates that accredited investors may participate in private offerings and other investment opportunities unavailable to non-accredited investors, underscoring the significance of any new qualification pathway.

For further information, contact John Byrne, Office Chief; Kenisha D. Nicholson, Senior Special Counsel; or Max Corey, Special Counsel, Office of Small Business Policy, Division of Corporation Finance, at 202-551-3460.