Oct. 6, 2026
In response to the proposed updates to the Accredited Investor qualification definitions. If the goal is to widen participation by those investors that have a duly recognized financial certification, then this proposal only does half the job. In the UK and across Europe, one can certify as a "financial professional" and invest in many semi-liquid fund products that are also allowed to be offered publicly (vs. US need to register as a 506c security) offering exposure to private markets. In the US, many of these same semi-liquid products already do not require the investor to be an Accredited Investor. So, if the rule change is aimed at increasing participation in privately offered funds, then not only does the update need to apply to Accredited Investor status, but it must also be applied to Qualified Client and Qualified Purchaser statuses, as most privately offered funds require an investor to meet all three of these designations not only Accredited Investor. Below is an excerpt from your brief dated Oct 5th in the Federal Register, and it is incorrect if a "pathway" to access "offerings by private funds" by these investors is truly your goal: "Qualifying for accredited investor status is significant because accredited investors may, under Commission rules, participate in investment opportunities that are generally not available to non-accredited investors, such as investments in private companies and offerings by private funds."