SEC Proposes Letting CFPs Qualify as Accredited Investors

TL;DR: The SEC is weighing whether CFP, CFA, and CPA credentials could qualify someone as an accredited investor without meeting the income or net-worth test, per the SEC's own proposal. The same package would let advisors charge performance fees up to 20% of gains, per CNBC. Nothing is final yet.

What the SEC Actually Proposed

The Securities and Exchange Commission voted on September 30, 2026, to propose a package of rule changes it's calling "Responsible Retailization of Private Markets," according to the SEC's own announcement. Separately, the commission opened a comment period on new ways to qualify as an accredited investor, as citybiz reported the same day.

The SEC's own resource list names the credentials under consideration: a CPA license, a CFA charter, a CFP certification, the FINRA Series 79, 86, and 87 licenses, and a new accredited-investor exam, per the SEC. None of that is adopted. It's a proposal open for public comment.

Today, qualifying mostly runs through a wealth test — a net worth over $1 million excluding your home, or income over $200,000 individually ($300,000 with a spouse) — or through certain licensed financial professionals, per Business Insider. This proposal adds credential-based doors next to the wealth-based one. It doesn't replace the wealth test.

Why Now: This Follows the 401(k) Executive Order

This didn't happen in isolation. SEC Chairman Paul Atkins tied the proposal directly to President Trump's executive order on "Democratizing Access to Alternative Assets for 401(k) Investors," saying the commission's work "complement[s] efforts undertaken pursuant to" that order, per the SEC. CNBC reports the plans are meant to draw more private asset managers into the retail wealth channel.

US financial advisors already allocate $1.9 trillion to fully liquid private-market strategies, a figure Cerulli Associates expects to grow to $3.7 trillion through 2029. A wider accredited pool is the pipeline for that growth. Access is not an edge, though. Judgment is, and a credential doesn't teach you to read a fee stack.

What the Performance-Fee Change Means for Advisors

Under the proposal, registered investment advisers could charge performance fees of up to 20% of a fund's net gains, a level CNBC describes as "comparable to fees historically used in the hedge fund and alternatives space."

That's a meaningful shift. Performance fees used to be gated by a separate, higher bar: advisors could only charge them to "qualified clients" with more than $1.4 million in assets under management with that advisor, or a net worth over $2.7 million, according to Business Insider. I covered that threshold change separately in our breakdown of the June 29 rule. This proposal is a parallel track. It widens who counts as accredited in the first place, not who counts as a qualified client once they're in.

Are Interval Funds Also Changing?

Yes. The SEC's own resource list names a separate "Interval Fund Modernization" proposed rule alongside the accredited-investor and performance-fee changes, per the SEC. The specific mechanics of that change aren't in the fact sheet language available as of this writing, so I'm not going to guess at them. Downside first: any loosening of repurchase rules changes how much cash a fund has to hold on hand for redemptions, the same tension I walked through in our look at interval fund redemption caps.

Do You Already Qualify as an Accredited Investor?

Verify before you trust a sponsor who tells you a new credential already works. It doesn't, not yet.

Path to accredited status	Status today	Under this proposal
Income: $200K individual / $300K with spouse	Qualifies	Unchanged
Net worth over $1M, excluding primary residence	Qualifies	Unchanged
Certain licensed financial professionals	Already recognized in some cases	Could expand
CPA license, CFA charter, CFP certification	Does not qualify	Would newly qualify, if adopted
FINRA Series 79, 86, or 87 license	Does not qualify	Would newly qualify, if adopted
Passing a new accredited-investor exam	Doesn't exist	Proposed as a new path

Source: SEC proposing-release resource list, September 30, 2026; Business Insider.

Common Mistakes to Avoid Right Now

Don't assume this is final. The SEC voted to propose these amendments and open them for public comment. It did not adopt them. A comment period, and likely revision, stands between here and any CFP or CPA actually using this route.

Don't confuse this with the qualified-client threshold. Accredited investor status gets you into Reg D private placements and most 3(c)(1) funds. Qualified-client status is the separate, higher bar that lets a fund charge you a performance fee. This proposal touches both, but they aren't the same gate, see the three SEC investor tiers explained if you're not sure which applies to you.

Don't assume a CFP, CFA, or CPA credential already works today. As of this writing, that door is proposed, not open.

FAQ

What are the new rules for accredited investors? The SEC has proposed letting CPAs, CFA charterholders, CFP holders, and certain FINRA license holders qualify as accredited investors, alongside new rules on advisor performance fees and interval fund liquidity. The amendments were proposed September 30, 2026, and aren't yet adopted.

How does the SEC define an accredited investor? Today, an individual generally qualifies by earning more than $200,000 a year ($300,000 with a spouse), by holding a net worth above $1 million excluding a primary residence, or through certain licensed financial credentials, per Business Insider.

What is the 10% investor rule? That's a different rule. It covers how much a non-accredited investor can put into a Regulation Crowdfunding offering based on income or net worth. It isn't part of this SEC proposal.

What are the requirements to be an accredited investor in 2026? As of this writing, the requirements haven't changed: the income test, the net-worth test, or certain professional credentials. The CPA, CFA, and CFP pathway is proposed, not adopted.

What to Do Today

If you're close to qualifying on the wealth test but hold a CFP, CFA, or CPA credential, don't restructure anything yet. The comment period hasn't closed. If you want to know the moment this becomes final, not when a sponsor tells you it is, that's what the free AIN newsletter is for. Sign up below and I'll flag it the day it moves.

Educational content only. Not investment, tax, or legal advice. Not an offer or solicitation to buy or sell securities. Past performance does not guarantee future results. Private-market investments are illiquid and involve risk of loss, including total loss of capital. Consult qualified advisers. Angel Investors Network is not a broker-dealer or investment adviser.