SEC would add a $100 exam as a route into private deals now gated at $1 million net worth
SEC proposes a FINRA-administered exam of about 75 questions and $100 as a new route to accredited investor status. A pass would stay valid for 10 years, so the fee works out to $10 a year.
The Investor · Invest desk
Four figures. The roughly $100 exam fee is about 0.01% of the $1 million net-worth threshold. Spread over a pass's 10-year validity, the fee works out to about $10 a year. The exam would have about 75 questions. Today's income test is $200,000 individually or $300,000 jointly.
- 0.01% Exam fee as share of net-worth bar, claim 14 About $100 vs the $1 million test
- $10 a year Exam fee per year of validity, claim 15 Fee spread over 10-year validity
- 75 questions Exam length, claim 4 Approximate; pass valid 10 years
- $200,000 a year Current income test, individual, claim 2 $300,000 jointly
| Figure | Value | Note | Claim |
|---|---|---|---|
| Exam fee as share of net-worth bar | 0.01% | About $100 vs the $1 million test | 14 |
| Exam fee per year of validity | $10 a year | Fee spread over 10-year validity | 15 |
| Exam length | 75 questions | Approximate; pass valid 10 years | 4 |
| Current income test, individual | $200,000 a year | $300,000 jointly | 2 |
What happened
- The plan would also let people qualify through professional credentials, including the CPA, CFA and CFP designations and certain FINRA licenses.
- Qualifying today mostly turns on money: $1 million net worth excluding the primary residence, or income of $200,000 individually or $300,000 jointly over the past two years.
- The package also carries related proposals for regulated funds, meant to broaden who can take part without removing investor protections.
- Coinbase CEO Brian Armstrong publicly backed the plan on October 11, 2026, arguing that retail investors have missed out on private markets for far too long.
- Public comment on the accredited investor notices closes December 4, 2026, and the proposals could still change before any rule takes effect.
Why it matters
- What it limits constraint The summary reports no passing score or pass rate, so the number of people the exam would newly admit cannot be sized from the fee, the length or the 10-year validity alone.
- Who's exposed exposure Anyone admitted through an exam or a credential becomes a buyer of assets that Crypto Briefing describes as typically illiquid, harder to value and more exposed to fraud than public stocks.
- Who has to decide decision Crypto Briefing calls tokenized and pre-IPO offerings a potential Coinbase opportunity, not an announced product, so the build decision can wait for the final text.
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Start with the fee. At about $100, the exam costs 0.01% of the $1 million net worth threshold it would sit beside [14], so a fee that low leaves the 75 questions to do all the screening [4].
The wealth tests were meant as a proxy for sophistication [10], and Armstrong's argument is that the proxy shut out a large group of people who could reasonably evaluate early-stage opportunities [8]. He framed the proposals as a "huge step forward" in democratizing private market access [7]. Critics of the current rules, as Crypto Briefing summarizes them, add that companies are staying private longer, so more of the value is created before an ordinary investor can buy a share [9]. That is a case against using wealth to measure knowledge. We think the net worth test also screened, crudely, for who could lose a position and carry on (or rather, it did that by accident, since nobody designed it to), and an exam can test only knowledge.
Atkins has emphasized expanding individual participation while guarding against investment fraud [13], and a cheap, long-lived pass fits the first half of that [4]. We'd expect the exam to come through comment in roughly this form. There are three specific ways that goes wrong. The fee or length could rise before the rule is final [12]. The exam could stay cheap and still go mostly untaken, so the widening exists in the rule text and barely in the market. Or the SEC could set a passing standard hard enough that few clear it.
What to watch
- Comment letters filed before December 4 on the exam's fee, length and passing score.
- Whether the final rule keeps the 75-question, $100, 10-year terms as proposed.
- Any Coinbase announcement of tokenized or pre-IPO offerings tied to the new eligibility routes.
Information, not investment advice. This story is general information about companies and markets, drawn from cited reporting. It is not a recommendation to buy, sell or hold any security; check the cited sources before acting.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence50
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- [1]
On September 30, 2026, the US Securities and Exchange Commission unveiled an overhaul of the rules that decide who counts as an accredited investor.
- [2]
Qualifying now mostly comes down to money: a net worth of $1 million excluding the primary residence, or income of $200,000 individually ($300,000 jointly) over the past two years.
- [3]
The proposals would add pathways for holders of professional credentials such as the CPA, CFA and CFP, along with certain FINRA licenses.
- [4]
The SEC proposed a new FINRA-administered exam of approximately 75 questions, costing approximately $100, with a passing result valid for 10 years.
- [5]
The package includes related proposals for regulated funds, designed to widen participation while keeping investor protections in place.
- [6]
On October 11, 2026, Coinbase CEO Brian Armstrong publicly backed the plan, arguing that retail investors have missed out on private markets for far too long.
- [7]
Armstrong framed the proposals as a "huge step forward" in democratizing private market access.
- [8]
Armstrong's core argument is that wealth thresholds have shut out a large group of people who could reasonably evaluate early-stage opportunities.
- [9]
Critics of the current rules say firms are staying private longer, so much of their value creation happens before ordinary investors can buy a single share.
- [10]
The wealth-based tests were meant as a proxy for sophistication.
- [11]
Private investments are typically illiquid, harder to value, and more exposed to fraud than public stocks.
- [12]
The public comment deadline for the accredited investor notices is December 4, 2026, and the proposals could still change before any rule takes effect.
- [13]
SEC Chairman Paul Atkins has emphasized expanding individual participation in private capital markets while still guarding against investment fraud and other risks to investors.
- [14]
The proposed exam fee of about $100 is about 0.01% of the $1 million net worth threshold.
- [15]
Spread over the 10-year validity of a pass, the roughly $100 exam fee works out to about $10 a year.
- [16]
Crypto Briefing says, citing its research findings, that Coinbase could position itself to facilitate tokenized offerings and pre-IPO investments under a clearer regulatory framework, and calls this a potential business opportunity, not an announced product.
Sources
2 independent publishers whose own reporting we read for this story.
- crowdfundinsider.comCoinbase CEO Welcomes Expansion of Accredited Investor Definition
1 article · October 12, 2026
- cryptobriefing.comCoinbase CEO Brian Armstrong praises SEC’s proposal for private market access
1 article · October 11, 2026
Topics and entities
Topics
- Private markets access
- Accredited investor rules
- Securities Regulation