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Obtaining Qualified Investor Status: A Memo


What gives the status of a qualified investor

A number of instruments on the exchange are available only to qualified investors, namely:

– investment units of closed-end mutual funds of the following categories: hedge funds, especially risky (venture) investments, credit, direct investments and long-term direct investments

– securities designated in accordance with the issuing documents for qualified investors

– foreign securities not listed on Russian stock exchanges

– from 2021 until the introduction of testing for unqualified investors – structured notes and products, as well as bonds with a high level of risk (presumably with a rating of BBB + and below). This will happen from the moment when the changes to the law made in December by the Central Bank come into force, and the Central Bank will adopt the relevant clarifying provisions.

As for derivative financial instruments, trading in them is available to all categories of investors, however, the law gives the exchange and broker the right to restrict certain transactions with derivatives in a general manner.


Requirements for obtaining the status of a qualified investor

In order to obtain the status of a qualified investor, you must meet one of the following criteria

1) Criteria for experience with securities

Making deals with financial instruments for the last 4 quarters, doing at the same time the following criteria

– with a frequency of at least 10 times / quarter on average, but at least 1 time / month

– in the amount of at least 6 million rubles.

2) Criterion of experience in the securities market

work experience in an organization from the field of securities and derivatives: if the organization is a qualified investor, then at least 2 years. If it is not, then at least 3 years.

This criterion takes into account work experience within 5 years prior to the date of application. Work experience is recognized as activities directly related to the performance of transactions with financial instruments (decision-making and recommendations on transactions, as well as control over transactions, financial market analysis and risk management)

3) Property criteria

Property size: not less than 6 million rubles. on the day of the corresponding calculation

In this case, property means: cash and accrued interest in credit institutions, financial instruments, financial instruments in a financial institution, unallocated metal accounts

Availability of assets and / or obligations from derivatives contracts: worth at least 6 million rubles.

4) Educational criteria

Appropriate education or possession of a qualification certificate

Such documents are understood as:

– a certificate of higher economic education (an economic diploma defined in the list of the Central Bank of universities, if it was obtained at the time when the university was conducting certification of citizens in the field of professional activity in the securities market)

– FFMS certificate of any series

– auditor’s qualification certificate

– qualification certificate of an insurance actuary,

– international qualifications CFA, CHA and FRM


How is the status of a qualified investor assigned

Step 1: The investor applies to the broker with a corresponding request and provides two documents:

– Application requesting the status of a qualified investor

– Documents confirming compliance with one of the above criteria (one document from the list below is enough)

In the case of property criteria – statements from the account of a credit institution, a depo account (Register of MBS owners), a report on the activities of the manager for managing financial instruments.

In the case of criteria related to the execution of transactions – broker’s reports on completed transactions, original / copy of documents confirming the performance of transactions with securities

In the case of the criteria of “experience” – a copy of the employment record book or employment contract. Also, if the organization was not a qualified investor, documents confirming the fact of its transactions in the securities market.

In case of education criterion – copies of the relevant documents

Step 2: The broker reviews the application and verifies the documents – the processing time for the application, as a rule, is about one working week

Step 3: In case of a positive decision, the individual is entered into the Register of Qualified Investors, to which each broker has access


The status is the same for all brokers registered in the Russian Federation. That is, it is enough to go through this procedure within one financial institution to be considered a qualified investor in all.

The law does not establish the period for which the status of a qualified investor is assigned to an individual, therefore, according to the general understanding of brokers, it is considered that this status is permanent. However, further development of legislation and the definition of this period cannot be ruled out.

The broker bears responsibility for the reasonableness of the inclusion of an individual in the Register, and the authorized person may, in some cases, reconsider the decision to assign the status of a qualified investor. In this interpretation, proposals for the “easy assignment of the status of a qualifying investor” for money carry more risks for the investor than guarantee the longevity of his status.

Prepared on the basis of materials from the Moscow Exchange



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