SEC's $100 Test May Expand Retail Access to Private Markets

People who lack $1 million in net worth or a $200,000 annual salary may soon be able to invest in private firms by taking an accredited investor exam that the SEC has released for public feedback.

Currently, a person's wealth determines accreditation status. Only accredited investors are permitted to purchase stakes in the majority of startups and private funds prior to a public listing.

What Would Be Tested in the Accredited Investor Exam?

Per an SEC notice, FINRA — the self-regulatory organization that licenses U.S. stockbrokers — would develop the exam.

The test would be open to anyone at least 18 years old. Participants would be given approximately two hours to answer roughly 75 multiple-choice questions, and the exam would be administered in person only.

The cost is expected to align with FINRA's basic broker exam, which now costs $100. A passing result would be good for a decade.

The largest portion of the exam — between 20% and 28% — would cover investment risks. Other topics would include financial statements, conflicts of interest, and corporate governance.

The SEC is also seeking input on whether CPAs, CFA charterholders, and CFP professionals should receive automatic accredited investor status.

Why Armstrong Backs the Plan and Who Opposes It

Coinbase CEO Brian Armstrong described the proposal as "a huge step forward" for investors who cannot afford private deals.

"For too long, only the richest people have had access to the private markets. Retail has been missing out," Armstrong wrote in an X post.

Crypto companies are already positioning themselves in this area. In September, MoonPay struck a deal to acquire North Capital, a Utah-based brokerage that handles private stock transactions.

Not all observers view the exam as a solution. SEC Commissioner Hester Peirce supports easier access but reportedly stated that a test still places the government in a gatekeeping role, per law firm Mayer Brown.

I'm not a fan of accredited investor gating, but at least we're proposing to nudge the gate open a bit: https://t.co/ylpd8v0SRV

— Commissioner Hester Peirce (Archived) (@PeirceArchived) September 30, 2026

Separately, Noah Damsky, a principal at Marina Wealth Advisors, told Financial Planning that the exam proposal is "horrible." He said that many private-market offerings are unsuitable for typical investors.

The timing of the proposal has also attracted criticism. PitchBook data shows that capital raised by private funds is set to decline for the fifth consecutive year.

PitchBook observed that because exits and distributions are lower, institutional investors have reduced cash to allocate to new funds.

Financial reform organization Better Markets connects the SEC's proposal to this fundraising decline. Benjamin Schiffrin, the group's director of securities policy, stated that private funds require retail capital "as institutional investors increasingly pull back from private markets."

Comments from the public are due by December 4. The exam is part of SEC Chair Paul Atkins' broader effort to expand retail access to private markets, which also includes a proposal to allow additional funds to charge performance fees.