Earlier we had from Pac-Man of all people, and in this regard I agree with him, “A black hat is a maaila that should be earned before one puts it on.”
When you have accomplished in Torah learning substantially more than a “run of the mill” Smicha, then a Black Hat can be considered.
A “run of the mill” Smicha is when your knowledge in Shulchan Aruch is no longer Botel B’Shishim (you know at least 1/60th of the Shulchan Aruch).