December 18, 2019
This comment is specifically directed at the use of financial designations and licenses as proxies for accredited investor suitability. I currently hold CFA, CFP, CAIA, FRM, PRM, CSCP, and insurance licenses. I previously have held FINRA licenses including 7, 63, and 65. I have in the past sat CPA licensing exams as well as actuarial exams.
I have severe doubts concerning allowing many of these licensees and designees be qualified as accredited investors. Certainly there may be individuals with these certifications who are capable of making informed investing decisions, however the vast majority would be out of their depth in measuring and managing the risk associated with these sophisticated investments.
I believe all active CFA charterholders are capable of making these evaluations. The other licensees on the whole, do not by virtue of these designations, necessarily have the requisite knowledge. Each of those designations may cover part of the knowledge required but are not comprehensive without additional designations.
CPAs and attorneys also fall into the category where those most likely to have the needed knowledge would also meet the income criteria making the designation or license requirement redundant.
I also caution against substituting years of experience for knowledge. Many Series 7 licensees, for example, do not have advanced knowledge gained through additional years of performing the same duties year after year. A broker/dealer or RIA is not likely to have gained additional knowledge after year 5 that they didn't already posses after their first year in the industry.
I believe a CPA or attorney with another license or designation would provide sufficient sophistication as an accredited investor. However even the advanced attorney and CPA licenses/designations do not provide the risk management evaluation necessary to perform an accurate evaluation of the inherent risk.
The greatest fear I have is that these investors will take a myriad of investments believing that they understand the risks involved or that by investing in a large number of high risk investments, they have diversified their risk.