
Becoming an ‘Accredited Investor' opens multiple investment opportunities, but very few know about it
Empower your mind, elevate your skills
The exclusive club
Have an annual income higher than or equal to Rs.2 crore.
Have a net worth greater than or equal to Rs.7.5 crore (with at least Rs.3.75 crore in financial assets).
Have an annual income higher than or equal to Rs.1 crore, plus a net worth greater than or equal to Rs.5 crore (with at least Rs.2.5 crore in financial assets).
Limited appeal
Access to differentiated investment opportunities
Pre-IPO deals, private equity, private credit, GIFT City AIF, among others.
Regulatory concessions Greater flexibility in exposure limits, tailored exit options, relaxation in fee structures.
Reduced entry thresholds Option to invest in products like PMS with a lower ticket size (see table below).
Lack of awareness among HNIs and family offices about benefits.
Service providers averse to lowering ticket size and lose high-value business.
Reluctance among investors to disclose financial details.
Tedious, restrictive process of accreditation.
Limited shelf life of accreditation.
Changes on the anvil
'Money, money, money, Always sunny, In the rich man's world.'Crooned by the iconic pop quartet, ABBA, once upon a time, this could well be the theme song for a small section of investors. The well-heeled suffer from a particular affliction: they find traditional investment boundaries insufferably pedestrian. While retail investors wade in the shallow end of mutual funds and fixed deposits, the truly affluent eye the deep end with its promise of uncharted returns.The 'accredited investor' designation offers precisely this distinction— a velvet rope separating the financial cognoscenti from the merely comfortable. The capital market regulator, Securities and Exchange Board of India (Sebi), has created a two-tiered system: the masses fish in heavily patrolled waters, while the certified wealthy venture where both rewards and sharks are considerably larger.This begs the question: does this badge of financial sophistication deliver on its promise of exclusivity—or is it merely an expensive regulatory theatre?Sebi had introduced the framework for accredited investors in 2021. The premise is simple: to carve out a less restrictive arena for a class of investors savvy and informed enough about the markets and having a bigger appetite for risk. It offers lighter regulations and relaxed investment norms that accord greater flexibility to investors to gain exposure to sophisticated financial instruments. It includes various regulatory concessions, such as access to exclusive investment opportunities, lower minimum investment thresholds, among other benefits.At its core, the idea of an accredited investor recognises that not all investors are equal, says Sandeep Jethwani, Co-Founder, Dezerv. 'Some investors possess the financial acumen and risk appetite to go beyond the standard investment requirements,' he adds. The purpose of creating a separate framework for accredited investors is to provide lighter-touch regulation, asserts Shobhit Mathur, Co-founder, Ionic Wealth by AngelOne. 'It serves an increasing tribe of high-value investors, who have a risk appetite and seek aspirational opportunities, not constrained by regulations.'To qualify as an accredited investor, individuals must meet one of the following financial criteria:The value of primary residence is not included while calculating the net worth. 'The net worth criterion allows considering the value of an unoccupied second house, providing some leeway to individuals,' points out Mathur. The income and asset values are considered on the basis of latest income tax returns or net worth certificate.If you fit the criteria, the accredited investor tag opens up a gamut of investment opportunities. 'Accreditation enables investors to access curated, high-quality opportunities that are often restricted to sophisticated participants,' says Sanat Mondal, Head of Private Markets from Sanctum Wealth.To be sure, bigger investors have the option of investing in differentiated products in the form of Portfolio Management Services (PMS) and Alternate Investment Funds (AIF). As per regulations, the minimum ticket size is pegged at Rs.1 crore for AIF and Rs.50 lakh for PMS. Accredited investors can circumvent these limits. If accredited, an individual may get to invest in a PMS for as low as Rs.10 lakh or an AIF for Rs.25 lakh. This reduced investment threshold allows the investor to take diversified exposure to 3-4 different strategies, rather than invest the entire sum in a single avenue. Mathur remarks, 'The accredited investor can start small and diversify across multiple strategies and scale up later.'Jethwani adds, 'Previously, you would commit your entire corpus to one fund manager. Now, you can diversify across two-three exceptional managers with the same capital, accessing varied strategies and risk profiles.'Apart from customised AIF and PMS offerings, an accredited investor can avail of multiple other opportunities. They can tap into private placements, pre-IPO deals, venture capital, private equity, hedge funds, and other alternative investments that are not available to the general public. Even the upcoming SIF (specialised investment funds), which have a minimum outlay of Rs.10 lakh, will be available to an accredited investor at a lower ticket size. This product combines the strategies of AIF and PMS with the favourable taxation of mutual funds. Accreditation also lowers the barriers to overseas investments housed in the GIFT City. While regular investors can access these AIF offerings for $1,50,000, an accredited investor can get in at $25,000. With the overseas liberalised remittance scheme (LRS) limits currently fixed at $2,50,000 per financial year, accreditation allows investors to put in smaller amounts in a single fund, leaving a sizeable chunk free for other pursuits. 'Home country bias is very high among India's HNIs. The GIFT City AIF route offers a good way to diversify overseas,' insists Mathur.'The purpose of creating a separate framework for accredited investors is to provide lighter-touch regulation.'CO-FOUNDER, IONIC WEALTH BY ANGELONEBesides, accredited investors get benefits beyond unique investment solutions. 'They enjoy lower minimum investments, greater flexibility in exposure limits, and more tailored exit options,' remarks Abhijit Bhave, a wealth management expert. For instance, in large value PMS (minimum investment of Rs.10 crore), accredited investors get the benefit of placing 100% of their investment in unlisted securities, compared to the 25% limit for regular investors (Rs.50 lakh minimum ticket size). Similarly, in large value AIF (minimum commitment of Rs.70 crore), accredited investors enjoy the privilege of allocating a higher percentage of their assets under management (AUM) to individual companies within the AIF category I & II (50%) and category III (20%), compared to regular investors, who must adhere to a 25% and 10% allocation, respectively.Accredited investors are also allowed relaxations in fee structures. 'Even as regular investors face a capped fee structure, limited to a maximum of 2.5% of assets under advice or Rs.1.25 lakh when it comes to engaging with RIAs, accredited investors may negotiate a more flexible fee arrangement,' points out Jethwani. This may include hybrid, performance-based fees. Further, the accredited investor can benefit from both advisory and distribution services via the same RIA. The strict rules barring advisers from offering products do not apply to this cohort of investors.Experts reckon getting accredited puts power back in the hands of individual investors. 'Reflecting on the accredited investor framework, it is clear that it isn't just about giving the wealthy a new set of privileges. It's an acknowledgement from regulators that you've earned the right to invest like a sophisticated professional,' asserts Jethwani.Despite its many benefits, the accredited investor framework has not found many takers. After four years, India is home to only 650-odd accredited investors (including partnerships firms, family trusts and corporates), according to Sebi. Comparatively, the USA boasts 24 million accredited investors.Mondal points to lack of awareness among HNIs and family offices about the accreditation process and its advantages. Reluctance of investors to disclose assets and income details is another impediment. Submitting proof of income, such as tax filings, audited financial statements, salary slips or income certificate, is a concern for some. 'In the mass affluent segment, reluctance to disclose full net worth due to multiple adviser relationships poses an additional hurdle,' points out Bhave. Apart from investors, the asset managers and financial advisers have also not warmed up to the concept yet. There may be some reservation among service providers to offer a lower ticket size and lose high-value business, suggests Mathur.'It's an acknowledgement from regulators that you've earned the right to invest like a sophisticated professional.'CO-FOUNDER,DEZERVSome market participants point to a tedious, restrictive process of accreditation. Certification for accredited investors is provided by accreditation agencies, which currently include only subsidiaries of stock exchanges or depositories (CDSL Ventures Limited and NSDL Data Management Limited). In other countries, due diligence is typically conducted via the funds or service providers in which investors are putting their money. The need for third-party verification via dedicated accreditation agencies complicates matters. While the onboarding process is largely smooth, the 3-4 week wait for certification remains a bottleneck, says Bhave. 'The process remains unnecessarily complex and lengthy, with just two operational accreditation agencies. The sequential nature is particularly problematic: investors must get accredited before fund managers can even begin formal discussions, creating delays in competitive deal environments,' asserts Jethwani. Market participants indicate that wealth managers and platforms find it easier to operate under standard KYC norms. Further, accreditation has a limited shelf life. When granted on the basis of fulfilling eligibility criteria for the preceding one year, accreditation is valid only for two years.The certificate is valid for a maximum of three years if the applicant meets the eligibility criteria for the preceding two financial years. At a cost of Rs.10,000 (two years) or Rs.14,500 (three years) for every accreditation certificate, this is a recurring expense. Experts feel there is not enough incentive to seek accreditation. 'Unlike in developed markets, accreditation does not consistently unlock differentiated pricing, lower fees, or exclusive rights,' says Mondal.Get accredited for fractionalised, relaxed access to unique financial products.To qualify as a Sebi-accredited investor, one must meet either of the below criteria:Note: Income tax return or net worth certificate must be submitted as proof. Value of the primary residence is excluded while calculating net worth.The general perception among industry participants is that the accredited investor framework is still in a formative stage and needs improvements. 'Regulatory clarity and incentives around accreditation are still evolving, especially on how it materially changes investment eligibility or compliance burdens,' says Mondal.Sebi has recognised the bottlenecks in the present machinery. It has recently floated a consultation paper, proposing some changes to the accreditation framework. First, eligibility criteria for accreditation agencies may be expanded, allowing all KRAs to function as accreditation agencies. With more accreditation agencies, the present capacity constraints should be eased while fostering more competition to facilitate cost-efficient servicing.Further, AIFs may be allowed to provisionally onboard an investor as an accredited investor, based on his due diligence, pending certification from an accreditation agency. 'The provisional onboarding proposal is particularly smart, allowing fund managers to conduct due diligence parallel to accreditation rather than sequentially. This should significantly reduce the time-to-investment without compromising verification standards,' says Jethwani.Further tweaks should give a shot in the arm to a fledgling, yet promising, concept. The adoption of accredited investor framework represents a natural evolution of a financial market growing in size and depth. It is a space to watch out for in the coming years.
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