The Securities and Exchange Commission issued five separate notices on the same day, each asking whether one professional credential should, by itself, qualify a person for accredited investor status — the status that decides who may buy into private offerings not registered with the Commission. All five are scheduled to be published in the Federal Register on Monday, October 5, 2026, and in each one the Commission says only that it is "considering" the designation.
What accredited investor status allows
Being accredited lets a person "participate in investment opportunities that are generally not available to non-accredited investors, such as investments in private companies and offerings by private funds," the Commission writes; the definition is meant to "capture persons whose financial sophistication renders the protection of the Securities Act's registration process unnecessary." Today a natural person already qualifies by net worth over $1,000,000 (not counting a primary residence), by income over $200,000 in each of the two most recent years, or by holding one of three securities licenses the Commission designated in 2020: the General Securities Representative license (Series 7), the Private Securities Offerings Representative license (Series 82), and the Investment Adviser Representative license (Series 65). Any of the five credentials under consideration would work the same way: a holder "would only themselves qualify as accredited investors and could not rely on their status as accredited investors to purchase securities on behalf of another person."
What each notice asks
- CPA license (File No. 4-932): over 650,000 active U.S. CPAs, per a NASBA estimate as of August 27, 2026.
- CFP certification (File No. 4-934): over 110,000 U.S. holders, per the CFP Board's estimate as of September 1, 2026.
- CFA charter (File No. 4-933): about 194,000 charterholders worldwide, per the CFA Institute's estimate as of August 10, 2026.
- Series 79 and Series 86/87 (File No. 4-935): about 57,000 Series 79 holders and about 5,900 Series 86 and 87 holders as of August 2026 — the Commission's own estimate, from figures FINRA staff gave Commission staff. Commenters proposed adding these licenses back in 2020; the Commission deferred, saying it would "consider these other credentials after first gaining experience with the revised rules," and now says a holder "would meet the requirements."
- A FINRA exam (File No. 4-931): this one does not test an existing credential — it would designate passing an exam that does not exist yet. Commission and FINRA staff have only "discussed the possibility"; FINRA staff have "formulated initial plans" and are "ready to proceed with the next stages of development." No exam has been built, and no date is given for one.
The standard, and what is not decided
Every notice works through the same four attributes, which Rule 501(a)(10) sets out as a "non-exclusive list" the Commission will consider rather than a strict test: that the credential arises out of an examination administered by a self-regulatory organization or other industry body, or is issued by an accredited educational institution; that the examination reliably and validly demonstrates comprehension and sophistication in securities and investing; that holders can reasonably be expected to have the knowledge and experience to evaluate the merits and risks of a prospective investment; and that holding it is made publicly available or is otherwise independently verifiable. In each notice the Commission states the credential described would meet that standard — but every document's action line reads "Notice; request for comment," not an order, and the Commission has designated nothing. Each notice names the other four by title in a footnote, under the same authority — Rule 501(a)(10) and Note 1 to paragraph 501(a)(10), which requires notice and an opportunity for public comment before the Commission may designate any credential. Still, each keeps its own file number and its own comment path, and none of the five documents read by this desk says whether the Commission will decide them together or on separate timelines.
The dates
The Federal Register's text for the scheduled October 5 issue already prints the dates: "This release was published in the Federal Register on October 5, 2026. Comments should be received on or before December 4, 2026." The Commission's own releases, each dated September 30 and filed with the Register on October 2, still carry that sentence bracketed — "[INSERT DATE OF PUBLICATION IN THE FEDERAL REGISTER]... [INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]." Either way, December 4, 2026 is 60 days after the scheduled October 5 publication, by this desk's count.
How to comment
Each notice is its own docket, with its own file number and its own comment form at sec.gov/comments/ followed by the file number: 4-932 for the CPA license, 4-934 for the CFP certification, 4-933 for the CFA charter, 4-935 for the Series 79 and Series 86/87 licenses, and 4-931 for the FINRA exam. The comment-form links for all five are listed below under Source links.
Comments may also go by email to rule-comments@sec.gov with the relevant file number in the subject line — each release says to put every file number on the subject line if commenting on more than one — or by mail to Vanessa A. Countryman, Secretary, Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090. Each release says the Commission posts all submitted comments publicly and asks that personal information not be included.
Source links
- Potential Designation of U.S. Certified Public Accountant License, File No. 4-932 (SEC release PDF)
- CPA designation comment form, File No. 4-932
- Potential Designation of Certified Financial Planner Certification, File No. 4-934 (SEC release PDF)
- CFP designation comment form, File No. 4-934
- Potential Designation of Chartered Financial Analyst Designation, File No. 4-933 (SEC release PDF)
- CFA designation comment form, File No. 4-933
- Potential Designations of the Series 79 and Series 86/87 Licenses, File No. 4-935 (SEC release PDF)
- Series 79/86/87 designation comment form, File No. 4-935
- Potential Designation of Passage of an Accredited Investor Exam To Be Developed by FINRA, File No. 4-931 (SEC release PDF)
- FINRA exam designation comment form, File No. 4-931
- Federal Register record, Potential Designation of U.S. CPA License, document 2026-20308
