In December of 2020, the SEC amended their definition of “accredited investor” to include investors who (among other things) hold professional certifications. I am interested in the Licensed Investment Adviser Representative (Series 65) pathway and the SEC makes the following claim:

Whether a person holds one of the designations in good standing is specific to that designation, and persons seeking accredited investor status under this category should consult FINRA rules and any state rules applicable to them. For example, a person seeking accredited investor status by passing the Series 65 exam would also need to be licensed as an investment adviser representative in her state and would need to comply with all state-specific licensing requirements (e.g., paying dues, etc.).

There are a number of exceptions to the registration requirements in my state however and I am trying to determine if I would be considered to hold the designation in good standing if I:

  1. Have an active Series 65 license
  2. Do not register with my state due to qualifying for a registration exemption
  • What do you mean b "exceptions"? do you mean the list in 14(b)? – Iñaki Viggers Feb 12 at 23:28
  • Yes, that is what I was referring to. – Absolute Zero Feb 13 at 0:24
  • FWIW, the accredited investor definition has included and dropped and regained this kind of provision at least once, so there may be old case law on point. – ohwilleke Feb 13 at 0:49

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