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Series 65 and Series 7: Are License Holders Accredited Investors?

Yes. Since December 8, 2020, anyone who holds a Series 7, Series 65 or Series 82 license in good standing is an accredited investor under Rule 501(a)(10) of Regulation D, whatever their income or net worth. The license has to be active: passing the exam alone does not qualify you, and a lapsed registration does not either.

This post explains the 2020 change, what "in good standing" means for each license, which ones need a firm, how a sponsor checks a license, and what the license does not do. For the income and net worth tests, see the accredited investor definition. Rules are as of October 2026.

What changed in 2020?

On August 26, 2020, the SEC adopted amendments to the accredited investor definition (Release 33-10824). One of them, Rule 501(a)(10), created a category for "any natural person holding in good standing one or more professional certifications or designations or credentials" that the SEC designates by order.

The same day the SEC issued the order (Release 33-10823), effective December 8, 2020, designating three licenses:

License Formal name Who administers the exam Firm sponsorship to sit for the exam
Series 7 General Securities Representative FINRA Yes: associated with and sponsored by a FINRA member firm (or other SRO member)
Series 82 Private Securities Offerings Representative FINRA Yes: associated with and sponsored by a member firm
Series 65 Investment Adviser Representative (Uniform Investment Adviser Law Exam) Developed by NASAA, administered by FINRA No

The rule lists what the SEC weighs before designating a credential: it comes from an exam run by a self-regulatory organization, industry body or accredited school; the exam shows knowledge of securities and investing; holders can be expected to evaluate an investment's merits and risks; and whether someone holds it can be checked publicly. The SEC said it could designate more credentials later by order. As of October 2026, the three above are the ones the SEC's compliance guide names.

What does "in good standing" mean?

The SEC's small entity compliance guide says good standing "is specific to that designation" and points holders to FINRA rules and any state rules that apply to them. It gives one example directly: a person who passed the Series 65 "would also need to be licensed as an investment adviser representative in her state" and comply with that state's requirements, such as paying annual fees.

For the Series 7 and Series 82, the license is a FINRA registration held through a member firm. FINRA's exam pages say candidates must pass the Securities Industry Essentials (SIE) exam as a corequisite to obtain the registration. FINRA Rule 1210 also provides that a person whose last registration as a representative ended two or more years before a new application generally has to requalify by exam.

In practice, good standing comes down to three questions:

  1. Is the registration currently active (not terminated, lapsed or expired)?
  2. For the Series 65, is the person actually registered as an investment adviser representative with a state, rather than only having passed the exam?
  3. Is the person free of a bar or suspension that ends the registration?
Situation Accredited under 501(a)(10)?
Active Series 7 registration through a broker-dealer Yes
Passed the Series 65, registered as an investment adviser representative in a state Yes
Passed the Series 65 but never registered with a state No: the guide says state licensing is also needed
Series 7 registration terminated three years ago No, unless the person qualifies another way
Holds the SIE only No: the SIE is not a designated license

Do you need a firm to hold a Series 65 or Series 7?

For the Series 7 and Series 82, yes. FINRA says candidates "must be associated with and sponsored by a FINRA member firm or other applicable self-regulatory organization (SRO) member firm" to take representative exams, and the SEC's order repeats it.

For the Series 65, the SEC's order notes that "an individual does not need to be sponsored by a FINRA member firm to take the exam," but adds that passing "does not convey the right to transact business prior to being granted a license or registration by a state." So you can take the Series 65 on your own, but accredited status needs the state license, and each state sets its own requirements for it. Check your state securities regulator's rules before assuming you can hold it independently.

This is why "get the Series 65 to become accredited" is not a shortcut for most people. It takes passing a 130-question exam (FINRA lists the fee as $187) and then meeting a state's licensing requirements for investment adviser representatives, and keeping them.

How does a sponsor verify a license?

In a Rule 506(c) offering, the sponsor must take reasonable steps to verify every purchaser. A license is public, so the check is usually simple:

  1. Take the investor's full name and their individual CRD number if they have one.
  2. Search FINRA BrokerCheck for Series 7 and Series 82 representatives, and the SEC's Investment Adviser Public Disclosure site for investment adviser representatives.
  3. Confirm the registration is current, not just that the exam was passed, and that the name matches the investor's verified ID.
  4. Keep a dated copy of the result in the deal's records.

The investor should also confirm in writing which category they rely on. A sponsor who knows the license has lapsed cannot rely on it. For the other verification routes, see accredited investor verification; for using the same public tools to check a sponsor, see how to research a sponsor on EDGAR and BrokerCheck.

A worked example (hypothetical, for illustration only). Maria earns $120,000 a year and has $300,000 of net worth excluding her home, so she fails the income and net worth tests. She works for a broker-dealer and holds an active Series 7. She is accredited under Rule 501(a)(10) and can invest $25,000 in a 506(c) apartment deal once the sponsor confirms her registration. If she leaves the industry and her registration ends, she stops qualifying under this category, and a later deal would need another route.

What does a license not do?

  • It does not make you a qualified purchaser. That Investment Company Act test generally needs $5 million in investments for an individual. See accredited investor vs. qualified purchaser.
  • It does not make you a qualified client for an adviser's performance fee under Advisers Act Rule 205-3, which has its own dollar tests.
  • It does not extend to your entities. An LLC you own is accredited under the all-owners test only if every owner is accredited; your license counts for you as one of those owners.
  • It does not change suitability or the deal's risk. A license holder can lose money like any investor.
  • It does not let you sell the deal. Using a license to buy as an investor is different from acting as a registered representative for the sponsor, which raises its own firm and compensation rules.

How DoorRaise fits in

DoorRaise helps sponsors raise equity for apartment buildings with 5 or more units from their friends and followers, and takes verified accredited investors only, under Rule 506(c) by default or 506(b). A Series 7, 65 or 82 license is one of the ways an investor can verify on DoorRaise: it is checked with FINRA BrokerCheck, and it is instant when the record matches the name on the investor's verified ID (otherwise usually within a business day). The other routes are a letter from an adviser or broker, income or net worth documents, or a minimum investment of $200,000 (or $1,000,000 through an entity). See the accreditation feature. Fees for sponsors are $1,500 to set up (non-refundable), $5,000 at closing (only if the deal closes) and $3,500 a year.

Raise your apartment deal from the people who already follow you.

DoorRaise is built for apartment buildings with 5 or more units: one link for the deal, escrow until closing and a standard fee card.

Sponsors can see the full fee card.

FAQ

Are Series 65 holders accredited investors?

Yes, if they hold the license in good standing. The SEC's guide says that for the Series 65 that means being licensed as an investment adviser representative in your state, not only passing the exam.

Can I take the Series 65 to become an accredited investor?

You can take the exam without a firm sponsor, but passing it is not enough. You also need the state license as an investment adviser representative and must keep it current, under your state's rules.

Is a Series 7 holder an accredited investor?

Yes, while the Series 7 registration is active. The registration is held through a FINRA member firm, and under FINRA Rule 1210 someone last registered two or more years before a new application generally has to pass the exam again.

What professional certifications make you an accredited investor?

The SEC's order designates the Series 7, Series 65 and Series 82, and the SEC's compliance guide names only those three. Other credentials, such as the CFA charter or a CPA license, are not on that list.

Does an expired license still count?

No. Rule 501(a)(10) requires holding the license in good standing at the time of the sale.

Sources

This article is general information, not legal or investment advice. Licensing rules differ by state, so confirm your own registration status with your firm or state regulator. Every investment can lose money. DoorRaise is not a law firm, broker-dealer, investment adviser or funding portal.

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