If you hold a self-directed plan, accredited investor status is the gate standing in front of many popular investments. Syndications, private funds, note funds, and private placements are nearly all offered under SEC Regulation D, and nearly all of them take accredited investors only. Right now you get through that gate by being wealthy enough. On September 30, 2026, the SEC opened a comment window on whether knowing enough should also get you through.
Nothing has changed yet, but this is a topic we are following closely. If the SEC moves forward, it would open a second doorway to accredited investor status, one that could benefit self-directed plan investors.
What the SEC proposed
The SEC issued five notices, each asking one question: should a particular credential, or a new exam, be enough on its own to make someone an accredited investor.
The authority to do this already exists. Rule 501(a)(10) of Regulation D lets the SEC designate professional certifications, designations, and credentials as qualifying an individual, and it does that by order after taking public comment. These five notices are the comment step. No rule is being rewritten, and the accredited investor definition itself is not being touched.
Each notice would create an additional knowledge-based route. The current tests do not change: $200,000 of individual income or $300,000 jointly over the two most recent years, or $1,000,000 of net worth excluding a primary residence. Anyone who qualifies on income or net worth today still will. The Commission notes that most credential holders already clear those numbers, and says the point is to reach the investors who do not.
With self-directed plans accreditation is measured on the person, and your plan inherits your status. A new route that qualifies an IRA or Solo 401(k) account holder will also qualify the plan.
Three actions came out of that September 30 meeting, and this group of notices is the one that has meaningful impact for self-directed plan holders. The other two are rule proposals: when a registered investment adviser can earn performance-based compensation, and a modernization of the interval fund framework that also opens a rules-based path for registered closed-end funds to issue multiple share classes. Both are aimed at fund sponsors and advisers rather than at individual investors.
The credentials under consideration
Following are the five notices. The Commission could designate all of them, some of them, or none of them.
| File No. | What would qualify you | Condition |
|---|---|---|
| 4-931 | Passing a new accredited investor exam developed by FINRA | Good for ten years from passing, then retake |
| 4-932 | U.S. Certified Public Accountant license | Active and in good standing in any of the 55 U.S. licensing jurisdictions |
| 4-933 | Chartered Financial Analyst charter | Charterholder membership current with CFA Institute |
| 4-934 | Certified Financial Planner certification | In good standing with CFP Board, continuing education included |
| 4-935 | FINRA Series 79, and Series 86 and 87 | License active, measured by FINRA's own standing rules |
The exam is the only one that does not exist yet. FINRA staff have formulated initial plans, and the notice lays out what they anticipate: roughly 75 multiple-choice questions, about two hours, in person, open to anyone 18 or older with no firm sponsorship required. It would cover securities definitions and structures, investment risks, disclosure and regulatory requirements, financial statements, conflicts of interest, and corporate governance. A pass would carry a ten-year shelf life, and FINRA would build a way for issuers to verify it.
The other four work differently, because they attach to credentials an investor either holds or does not, and that are already publicly verifiable. That path also has precedent. Holders of Series 7, 65, and 82 licenses were designated as accredited back in August 2020, alongside the adoption of Rule 501(a)(10) itself.
If you carry a CPA license, a CFA charter, a CFP certification, or any of the three proposed FINRA Series licenses, the question of whether your credential counts is open in front of the Commission right now. It will not be open long.
Whether this is good for investors
Expanding access to private markets is not universally accepted as a good idea, and some of the concerns merit consideration. Private offerings carry less disclosure, less liquidity, and less recourse than registered securities, a point Chairman Atkins made in the remarks introducing these proposals. Widen the door and more people walk into a market where the losses are real and the safety net is thinner, some of them without understanding what they gave up.
That argument lands differently for an investor who has already left the walled garden. Choosing a self-directed structure means accepting that asset selection, diligence, and the liability for both belong to you as the account holder. The gatekeeping premise, that an investor is safer confined to what a brokerage is willing to sell, is one self-directed plan holders have already weighed and declined. For someone who brings in a CPA or an attorney where the deal warrants it, a wider menu of investment choices can be approached responsibly.
Not the same as private assets in your employer 401(k)
Keep this separate from the other story in circulation. The SEC's release ties this work to Executive Order 14330, signed in August 2025, which directed the Department of Labor to revisit its fiduciary guidance on alternative assets and asked the SEC to consider the accredited investor and qualified purchaser rules among other things. The two efforts are connected at that level. What each one would actually deliver is not the same.
That order concerns alternative assets inside conventional employer-sponsored plans, reached through asset allocation funds a plan fiduciary elects to offer. Access happens at the fund level, and the participant chooses from what the plan puts on the menu. The five notices recently issued by the SEC concern who is eligible to buy private securities directly, for their own account.
In a self-directed plan nobody assembles the menu. Any eligible offering a plan holder can source and vet is available to them.
How to comment, and by when
The five notices were published in the Federal Register on October 5, 2026, which sets the comment deadline at December 4, 2026. Each one takes comments separately, so a view on the CPA designation does not extend to the exam file. Use the comment form linked from the notice itself, or email rule-comments@sec.gov with the file number in the subject line. Comments are posted publicly and in full, so leave personal information out of them.
The exam notice asks three questions, and they work as a frame for any of the five: should the Commission make the designation at all, does it raise investor protection concerns specific to the people it would qualify, and does the credential or exam actually test what it would need to test. Anyone who has sat the CFA exams, carried a CPA license through a few renewal cycles, or read a private placement memorandum as a plan holder deciding whether to wire the money can answer at least one of those from experience rather than theory.
Eligibility today runs on the rules in effect today, and those have not moved.