Subject: File No. S7-25-19
From: Adam Moehn, CFA

March 8, 2020

I support the proposal to add a new category in the accredited investor definition for natural persons who hold certain professional certifications or designations or other credentials. It makes sense that such individuals that have achieved an appropriate certification, designation, or credential have proven the sophistication necessary to qualify as an accredited investor.

I support the Chartered Financial Analyst (CFA) designation to be a qualifying designation. This designation requires 3 levels of rigorous exams on investment analysis and portfolio management as well as requiring qualified work experience. Completing this program takes on average 4 years and 300 hours of studying for each of the 3 exams.

The CFA designation is already recognized by many other institutions. For example, FINRA exempts individuals from the series 86 exam if they have passed levels I and II of the CFA exams.

More information on the requirements for this designation are available at:

A list of the many waivers the CFA designation currently provides is available at: