Oct. 25, 2026
Dear Ms. Countryman: My name is Matthew Chlopek, and I am the founder and wealth advisor of Paladin Wealth Services, an independent, family-owned fiduciary firm based in Naples, Florida. I began my career in financial services in 2016 at Bank of America Merrill Lynch and later worked at Fidelity Investments, where I led a team serving individuals and families with a wide range of financial needs. Those experiences gave me a firsthand perspective on how investors make decisions, the importance of financial education, and some of the shortcomings of our financial services industry. I am writing in strong support of establishing a FINRA-administered examination as an alternative pathway to accredited investor status. Financial wealth should not be confused with financial knowledge. One of my fundamental disagreements with the current accredited investor framework is its reliance on income and net worth as the primary measures of an individual's ability to participate in private investment opportunities. Throughout my career, I have worked with individuals possessing substantial wealth who had relatively little understanding of investments, financial markets, or the risks associated with certain financial products. Conversely, I have encountered individuals with considerably fewer financial resources who demonstrated a much greater understanding of these subjects. Having significant financial resources does not necessarily make someone a knowledgeable or sophisticated investor. Likewise, having fewer financial resources should not automatically disqualify someone who has taken the initiative to educate themselves. I recognize that an investor's financial capacity to withstand losses is an important consideration. However, that is a separate issue from their ability to understand and evaluate an investment opportunity. Financial education should create opportunity. I am a strong believer in individual liberty, personal responsibility, and the importance of providing people with opportunities to improve their circumstances through education and hard work. Our current accredited investor framework creates a situation where someone can qualify for certain investments simply because they inherited substantial wealth, while another individual who has dedicated years to studying financial markets and investment principles may be excluded. I struggle to see the fairness in that approach. I work extensively with families who are concerned about preparing the next generation to become responsible stewards of their wealth. An important part of that process involves helping children and grandchildren develop financial literacy, sound judgment, and an understanding of the responsibilities that accompany ownership. I would much rather see an individual earn access to investment opportunities by demonstrating knowledge and understanding than receive that access solely because of their financial circumstances. A properly designed examination would encourage financial education while providing a meaningful pathway for individuals who might otherwise remain excluded. Investor protection should emphasize education and informed decision-making. I take investor protection very seriously. As an independent fiduciary, I believe financial professionals have a responsibility to educate clients, explain risks clearly, and help individuals understand what they own and why they own it. Unfortunately, I have witnessed firsthand how the financial services industry can sometimes fall short of those responsibilities. Financial products are not always presented with the clarity they deserve. Important distinctions between investments can be overlooked, and investors may not fully appreciate the risks, costs, liquidity restrictions, or other considerations associated with an investment. These concerns exist regardless of an investor's net worth. For that reason, I would encourage the Commission and FINRA to develop an examination that emphasizes practical financial knowledge and sound decision-making rather than memorization. Specifically, I believe the examination should address: Understanding investment documents: Evaluating offering memoranda, fee structures, financial projections, and important disclosures. Recognizing investment risks: Understanding illiquidity, leverage, concentration risk, potential loss of principal, and the unique characteristics of private investments. Evaluating fees and conflicts of interest: Identifying compensation arrangements, incentives, and other factors that may influence how an investment is presented. Conducting appropriate due diligence: Understanding how to evaluate investment sponsors, verify information, and recognize potential warning signs of fraud or misrepresentation. Exercising sound judgment: Recognizing when an investment may be inappropriate, regardless of its potential returns or the enthusiasm surrounding it. These are foundational concepts that I believe every investor would benefit from understanding. I would also encourage the examination to emphasize that passing a test does not automatically make every investment appropriate for an individual. Knowledge is important, but so are financial circumstances, investment objectives, risk tolerance, and the ability to withstand losses. Accessibility should be an important part of implementation. If the objective is to expand opportunities for knowledgeable investors, the examination itself should be reasonably accessible. I would encourage FINRA to offer a remotely administered examination, similar to existing online testing options, and to keep the cost affordable, ideally at or below $100. I would also recommend establishing a secure verification process that allows issuers to confirm an individual's qualification without unnecessarily disclosing personal information or creating publicly accessible lists of qualified investors. The process should be straightforward, affordable, and designed to encourage participation from individuals willing to invest the time and effort to become educated. A meaningful opportunity for future generations. Much of my work as a wealth advisor revolves around helping families make thoughtful financial decisions, preserve what they have worked to build, and prepare future generations to become responsible stewards of their resources. I firmly believe that financial knowledge is one of the most valuable things we can pass along to the next generation. Our country has long valued the idea that individuals should have opportunities to improve their circumstances through education, initiative, and personal responsibility. I believe the accredited investor framework should reflect those same principles. An examination-based pathway would not eliminate investment risk, nor should it replace the importance of appropriate due diligence and investor protections. However, it would recognize something the current framework largely overlooks: financial sophistication can be developed through education and experience, and should not be presumed solely from a person's wealth. I respectfully encourage the Commission to move forward with this initiative and establish a rigorous, practical, and accessible pathway to accredited investor status. Thank you for considering my comments and for the Commission's continued work on these important issues. Respectfully, Matthew A. Chlopek, CRPC® Founder, Wealth Advisor