
The SEC wants to let people test their way into accredited investor status. I think an accredited investor exam can prove what you know, but it cannot prove what protects you.
On September 30, 2026, the SEC proposed new credential pathways to the accredited investor definition. The list includes the CPA license, the CFA charter, the CFP certification and several FINRA licenses. It also floats an exam that FINRA would develop.
This is a proposal, not a rule. The Federal Register notice asks for public comment until December 4, 2026.
What the accredited investor exam would change
Today, most individuals qualify on money: income or net worth above set thresholds. An exam adds a second door. You show knowledge instead of a balance.
That is a fair idea. Wealth and wisdom are not the same thing, and the current definition treats them as if they were.
I run Raveum, a platform for diversified US commercial real estate (net lease, self-storage, multifamily and other income-producing commercial property). In our US route we verify investors under Rule 506(c), the Regulation D rule that allows an offering to be advertised as long as every buyer is verified. So I think a lot about what verification is for.
What a test can prove
A test can show that someone understands how a private offering works. That means illiquidity, thinner disclosure than a public company, and the fact that a loss can reach the full amount invested.
It also makes my job cleaner. A test result is easier to check than a stack of tax returns and brokerage statements.
Professional credentials add something else. Most come with conduct rules and a body that can take the credential away. A bank balance carries no such accountability.
What a test cannot prove
A passing grade proves what a person knew on the day they sat the exam. It does not prove they can absorb a total loss. It does not prove the investment is a small part of their balance sheet. It does not prove they will stay calm when they cannot sell for years.
Picture a CFA charterholder with a modest salary and a large mortgage. The charter says they understand risk. It says nothing about whether they could lose a year of savings and still pay for their children's school fees.
Capacity to lose money is a financial fact. Understanding that you can lose money is a knowledge fact. The current thresholds are crude, but they at least point at the first one. An exam points at the second.
Neither one tells you whether an investment suits a particular family. That is a conversation for a qualified advisor, not a blog post.
The trade-off I would weigh
If I were writing a comment letter, I would ask for two things. Keep verification mandatory, so an exam result is checked and never self-declared. And keep plain risk disclosure in front of every person who qualifies by test, because someone who passed an exam can still be surprised by a lock-up.
There is also a design question for the exam itself. A test anyone can pass after a weekend of study proves little. A test that is too hard becomes a gate for people with time and tutors. The SEC has to find that line, and the comment period is where the argument gets made.
The cost of tighter verification is friction and time. I accept that cost. In a 506(c) offering, verification is the control, not the paperwork around it.
Nothing changes today, and anything final could look different from this proposal. A test can open a door, but it cannot make a loss affordable.
If you could design the credential, would you test what people know, what they can afford to lose, or both?
This post reflects my personal views and is for general education only. It is not investment, tax or legal advice. Investing involves risk, including loss of capital, illiquidity and currency movements, and past performance does not indicate future results. Raveum offerings are available only to eligible investors in the countries Raveum serves, under the applicable securities exemptions, and are not open to the general public. Speak to a qualified advisor and your own bank or CA about your situation.
