On September 30, 2026, the SEC issued six notices that would add new ways for individuals to qualify as accredited investors. Most early coverage treated the news as a story about investors. The SEC accredited investor proposal matters just as much to real estate sponsors who raise under Rule 506(c). It could change who a sponsor may admit and how that sponsor confirms each person's status. None of the new pathways has been adopted, and each now faces a 60 day comment period that begins when the notices appear in the Federal Register.
The central point for sponsors is that a credential is easier to check than a balance sheet. Today a sponsor raising under Rule 506(c) usually verifies income or net worth. That means reviewing tax forms, brokerage statements or a letter from a CPA or attorney, as Raveum's guide to accredited investor verification under 506(c) sets out. If the SEC designates the new credentials, part of that work could shift to looking up a license in a public directory. Sponsors who plan now, while the proposals are still open, can update their documents and onboarding steps without a rush later.
What the SEC Accredited Investor Proposal Would Add
The SEC acted under Rule 501(a)(10) of Regulation D, which it adopted on August 26, 2020. The rule lets the agency designate professional certifications as a basis for accredited status. Under that rule, the SEC may designate a credential only by order, after notice and an opportunity for public comment. The first designations covered holders of the Series 7, Series 65 and Series 82 licenses, which still qualify today according to the SEC's page on accredited investors. The new notices would extend the same treatment to six further credentials.
- Passing an accredited investor exam that FINRA would develop, which does not yet exist
- A U.S. certified public accountant license in good standing
- A Chartered Financial Analyst charter in good standing
- A Certified Financial Planner certification issued in the United States
- An active FINRA Series 79 investment banking representative license
- Both the FINRA Series 86 and Series 87 research analyst licenses
Morrison Foerster's summary of the notices puts the number of CPA license holders at about 650,000 and CFA charterholders at 194,000 worldwide. Those figures describe the size of each professional group, not how many people would ever choose to invest in a private offering. In the SEC's September 30 press release, Chairman Atkins said one of his priorities is to "explore ways to facilitate the ability of individual investors to participate in private markets." He paired that aim with protecting those investors from bad actors and fraud. Sponsors should expect the final orders to strike the same balance.
Why the Proposals Are Not Yet Rules
The notices are a first step, and sponsors should treat them that way. The SEC framed each one as a potential designation. Morrison Foerster noted that no orders have been issued and that the agency has not yet decided to designate any credential. Comments are due 60 days after each notice is published in the Federal Register, and the SEC may then adopt, change or drop any of the six. The exam route has the longest path ahead. FINRA would still need to build the exam and a way for issuers to confirm that a person passed it.
Until an order is final, the existing tests remain the only ones a sponsor can rely on. According to the SEC, a natural person qualifies with income over $200,000, or $300,000 with a spouse or partner, in each of the prior two years. A net worth over $1 million, excluding a primary residence, also qualifies. Holders of the three licenses designated in 2020 qualify as well. A sponsor that admits a CPA or a CFA charterholder today must still verify that investor through income, net worth or one of those licenses.
How Credential Pathways Could Change 506(c) Verification
Rule 506(c) lets a sponsor advertise an offering broadly, a practice known as general solicitation. In return, the sponsor must take reasonable steps to verify that every purchaser is accredited. The SEC's notice on the CFA charter repeats that "issuers must take reasonable steps to verify that all purchasers are accredited." It adds that a charterholder's good standing "could be easily independently verified" through the CFA Institute's public member directory. According to Morrison Foerster, similar public lookups exist for the other credentials. They include CPAverify for accountants, the CFP Board's website for planners and FINRA BrokerCheck for the Series 79, 86 and 87 licenses.
For a sponsor, that changes the shape of the verification file rather than the duty behind it. Checking a public directory asks far less of an investor than handing over two years of tax returns. It also leaves a clear record of what the sponsor saw and when. Even so, a credential has to be in good standing at the time of the sale. The check therefore belongs close to closing rather than at first contact. Sponsors still choosing a Rule 506 exemption can see how verification shapes that choice in this comparison of 506(b) and 506(c) for real estate sponsors.
Who Might Become Eligible and What That Means for Marketing
The professionals named in the notices are people many sponsors already meet. Accountants, financial planners, analysts and investment bankers attend industry conferences, follow sponsors on LinkedIn and often advise the families that sponsors hope to reach. Some of them do not meet today's income or net worth tests, so a sponsor marketing a 506(c) deal publicly cannot admit them now. If the designations are adopted, some of the people that marketing already reaches could qualify on the strength of their credential instead.
That shift calls for care rather than excitement. A credential shows financial knowledge, but it says nothing about whether a particular investment suits a particular person. Private real estate still carries the risk of loss of capital, illiquidity, falling property values, tenants leaving and distributions not being paid. Sponsors who admit credential holders should describe those risks as plainly as they would to any other investor, and they should keep each investor's route clear. Investors outside the United States who come in under Regulation S follow a separate set of conditions, which Raveum's Regulation S guide for real estate sponsors explains.
What Sponsors Can Do Before a Final Order
The practical work starts with documents. Sponsors can ask securities counsel to review subscription agreements and investor questionnaires so that new credential categories can be added quickly if the SEC adopts them. They can also decide which directory would confirm each credential, who on the team would run the check and where the record would be kept. Sponsors with views on the proposals, including how passage of the FINRA exam should be confirmed, may file a comment with the SEC before the deadline. Until then, every investor should qualify and be verified under the existing tests.
Raveum offers sponsors four solutions, which are an investment management platform, fund administration, a global raise track under Regulation S and an operating partnership for selected sponsors. U.S. investors come in under Rule 506(c) and receive K-1s, and sponsors keep their investor relationships, their property and their business plan. See how the Raveum Sponsor Program works.
A Credential Is a Starting Point for Verification
The September 30 notices rest on a simple idea, that knowledge can stand alongside wealth as a test for private markets. For sponsors, the more immediate consequence is administrative, because a designated credential would change what a sponsor checks and records before accepting a subscription. Nothing has changed yet, and the final orders may differ from the notices. Sponsors who follow the comment period and prepare their documents now will be ready for whatever the SEC adopts. Raveum's accredited investor verification guide covers the steps that apply today.
Frequently Asked Questions
Has the SEC Changed the Accredited Investor Definition
No. On September 30, 2026, the SEC issued notices proposing to designate six new credentials, but it has not issued any final order. Comments are due 60 days after each notice is published in the Federal Register. Until the SEC adopts an order, sponsors should qualify and verify investors only under the existing income, net worth and license tests.
Which Credentials Would Qualify Under the SEC Proposals
The notices cover six credentials. They are a new FINRA accredited investor exam, a U.S. CPA license, a CFA charter, a U.S. CFP certification, the Series 79 license, and the Series 86 and 87 licenses held together. They would join the Series 7, 65 and 82 licenses, which the SEC designated in 2020. Most would need to be held in good standing.
How Would a Sponsor Verify a Credential Under Rule 506(c)
A sponsor would most likely confirm the credential in a public directory, such as CPAverify, the CFA Institute member directory, the CFP Board website or FINRA BrokerCheck. The duty to take reasonable steps to verify each purchaser would not change. Securities counsel should confirm what record to keep, and the check should happen close to the date of sale.
Does a Credential Make an Investment Suitable for an Investor
No. A credential would show financial knowledge, not that a specific offering fits a specific person. Private real estate carries the risk of loss of capital, illiquidity, falling property values and distributions not being paid. Sponsors should disclose those risks plainly to every investor and work with securities counsel on how they market to and admit newly eligible investors.
This article is for general education only and is not legal, tax or investment advice. Securities and tax rules change and depend on each sponsor's facts, so work with qualified securities counsel and tax advisors before launching an offering. Real estate investments involve risk, including loss of capital, illiquidity and changes in property values. Offerings on Raveum are available to eligible investors only and are not open to the general public.
