SEC Hikes Rich Threshold: Now $1.2M to Pay for Success Fees
Published Date: 5/1/2026
Notice
Summary
The SEC just bumped up the dollar amounts that let investment advisers charge performance fees to their clients. Now, to be a “qualified client,” you need a bit more money—$1,200,000 in assets or $2,400,000 in net worth—thanks to inflation. This change helps keep the rules fair and kicks in right away, affecting advisers and wealthy clients who want performance-based fees.
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Analyzed Economic Effects
3 provisions identified: 0 benefits, 2 costs, 1 mixed.
Assets threshold for 'qualified client' rises
To be a “qualified client” for performance-fee contracts, you now must have at least $1,400,000 under the management of your investment adviser immediately after entering into the contract (previously $1,100,000). This change was ordered under rule 205-3 and takes effect June 29, 2026.
Net-worth test for 'qualified client' increases
To meet the net-worth test to be a “qualified client,” you now must have a net worth of more than $2,700,000 (including joint assets with a spouse for individuals) immediately prior to entering the contract (previously $2,200,000). The adjustment reflects inflation and is effective June 29, 2026.
Effective date & contract transition rules
The order takes effect June 29, 2026. Dollar-amount adjustments generally do not apply retroactively to contractual relationships entered into before that date, subject to the transition rules in rule 205-3 (for example, advisers who entered contracts under the prior tests are generally treated as satisfying the prior conditions).
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