The short answer
Not by passing the exam alone. Since December 8, 2020, Rule 501(a)(10) and the SEC's accompanying order accredit a natural person holding in good standing a Series 7, Series 82 or Series 65 licence. The SEC's adopting release is explicit that passing the Series 65 does not convey the right to transact business until a state grants a licence or registration, and that to qualify as an accredited investor the holder must maintain that state-granted registration in good standing. The Series 7 and 82 cannot even be taken without a sponsoring FINRA member firm. For a rental seller the licence route is therefore a path for people already working in the industry, and the practical test remains net worth, where the equity in the building being sold counts.
At a glance
| Rule | Rule 501(a)(10): natural persons holding in good standing a professional credential the SEC designates by order |
|---|---|
| Designated so far | Series 7, Series 82 and Series 65, by SEC order of August 26, 2020 |
| Effective | December 8, 2020 |
| Series 65 catch | Passing the exam conveys no right to do business; good standing means a state-granted licence or registration kept current |
| Series 7 and 82 | Only available to people associated with a FINRA member firm |
| Practice requirement | None in the rule; the credential must be held in good standing, not used in a job |
| How sponsors check | FINRA BrokerCheck and the SEC's Investment Adviser Public Disclosure database |
| Not designated | CPA, CFP, bar admission, real estate licences and other credentials, unless the SEC adds them by a later order |
What the 2020 amendments added, and what they left to a separate order
The SEC announced the amendments on August 26, 2020. Rule 501(a)(10) now covers any natural person holding in good standing one or more professional certifications, designations or credentials that the Commission designates by order. The rule itself names no credential; the designation lives in Release 33-10823, an order issued the same day.
That order finds that three licences meet the rule's attributes and orders that the General Securities Representative licence (Series 7), the Private Securities Offerings Representative licence (Series 82) and the Investment Adviser Representative licence (Series 65) shall qualify natural persons holding such licences in good standing as accredited investors. It adds that the determination may be reconsidered if the licensing requirements change significantly.
Both the rule and the order became effective December 8, 2020, the date stated in the adopting release. The same amendments added the spousal equivalent to the income and net worth tests, which whether a spouse's income counts toward accreditation covers.
Why the Series 65 looks like an open door, and what good standing actually requires
The Series 65 is the one licence on the list anyone can sit. The adopting release notes that the North American Securities Administrators Association developed the exam, FINRA administers it, and no member-firm sponsorship is needed to take it. Hence the idea that circulates: pass one exam, become accredited, buy the trust.
The release closes the door in the next sentence. Successful completion of the exam does not convey the right to transact business prior to being granted a licence or registration by a state, and, in the release's words, to qualify as an accredited investor a Licensed Investment Adviser Representative must maintain, in good standing, the individual's state-granted licence or registration. The credential is the registration, not the score report.
The SEC's investor bulletin says the same from the investor's side: whether one is in good standing is specific to the designation, and people seeking accredited status as a Series 7, 65 or 82 holder should consult FINRA rules and any state rules that apply to them. Becoming registered as an investment adviser representative is a state licensing process with its own conditions, which this page does not cover.
The Series 7 and 82 are closed unless you work at a member firm
The order's own footnotes set out the entry conditions. An individual must be associated with a FINRA member firm or another self-regulatory organisation member to be eligible to take the Series 7 and be granted the licence, and must be associated with and sponsored by a member firm to take the Series 82. Neither is available to a private investor who wants the credential for its own sake.
Good standing for those two licences is tied to the firm. The adopting release observes that General Securities Representatives and Private Securities Offerings Representatives are subject to continuing education requirements under FINRA rules in order to keep their designations current. Leave the firm and let the registration lapse, and the credential stops qualifying you, whatever you once passed.
The release does not require the holder to practise in the field, except where continued affiliation with a firm is needed to keep the credential. Whether a state keeps an adviser representative registration active for someone not employed by an adviser is a question of state rules and could not be confirmed here.
How a sponsor checks, which is why a bare exam pass will not get through verification
A Rule 506(c) sponsor must take reasonable steps to verify your status, and the adopting release explains why these three licences were chosen: readily available information on whether an individual actively holds the credential is useful for that purpose, and issuers can obtain registration and licensing information easily through FINRA's BrokerCheck or the Commission's Investment Adviser Public Disclosure database.
A passed Series 65 with no state registration produces no record in either system, so a sponsor checking the licence route finds nothing to verify. The documentary routes for the other two tests, and the three-month limit on net worth statements, are explained in whether accreditation has to be verified for a 1031 DST.
The licence route is also personal to the holder. Rule 501(a)(10) speaks of a natural person holding the credential; unlike the income and net worth routes, it has no joint version with a spouse or spousal equivalent, so a spouse's registration does not accredit you.
For a rental seller, the net worth test is almost always the shorter road
Rule 501(a)(5) excludes only the primary residence. The equity in the rental you are selling counts, so do the exchange proceeds once it closes, and so do retirement and brokerage accounts; what counts toward the $1 million net worth test runs the list. A seller with $400,000 of rental equity and $650,000 across an IRA and a brokerage account is already over the line, with no exam.
If neither net worth nor income gets there, the exchange still works without any licence: real estate you buy directly needs no accreditation, and selling a rental when you are not an accredited investor sets out that path. A credential that opens the door does not make the room safer: a DST interest cannot be sold on demand, the sponsor sets the exit, and principal can be lost.
Treat the licence route as a fact about people already registered, not as a plan for the next 45 days, and check your own net worth and income figures with your CPA before you identify anything.
Related questions
If I pass the Series 65 but never register, does the pass expire?
The SEC's materials say only that passing conveys no right to do business until a state grants a registration. How long a state will honour an exam pass before requiring a retake is set by state rules and was not verified for this page; ask the state securities administrator.
I am a CPA or hold a CFP. Does that make me accredited?
No. Only the Series 7, 82 and 65 have been designated by order. The SEC said it may add other credentials by later order, and its accredited investor page still lists only these three.
My spouse holds a Series 7. Am I accredited?
Not through the licence. Rule 501(a)(10) applies to the natural person holding the credential and has no joint version. Your spouse's income and net worth do count toward the joint tests in Rule 501(a)(6) and (a)(5).
Does the licence route need documents under Rule 506(c)?
The sponsor still has to take reasonable steps, but the adopting release points to BrokerCheck and the adviser disclosure database as the ready sources, so a current registration record is usually what it checks.
Would becoming registered change my 1031?
No. Section 1031 has no wealth or licence test, and Rev. Rul. 2004-86 treats a DST interest as real property regardless of who holds it. A registration only changes which private offerings may sell to you.
Sources
Checked against these publications on October 8, 2026. Rules and figures change; confirm the current version with your CPA or attorney before you act. This page is general information, not tax or legal advice.
- 17 CFR 230.501, Regulation D definitions (Rule 501(a)(10))
- SEC, Order Designating Certain Professional Licenses as Qualifying Natural Persons for Accredited Investor Status, Release 33-10823 (August 26, 2020)
- SEC, Amending the Accredited Investor Definition, Release 33-10824 (effective December 8, 2020)
- SEC press release 2020-191, SEC Modernizes the Accredited Investor Definition (August 26, 2020)
- SEC Office of Investor Education and Advocacy, Accredited Investors: Updated Investor Bulletin (April 14, 2021)
- 17 CFR 230.506, Rule 506(c) verification