Okay, I'll give you two. First, let's suppose that you're interested in distance learning for an M.Div. degree in order to become a pastor in a particular denomination. If that denomination supports an unaccredited seminary, and considers graduates for ordination, then such an unaccredited institution may suit your needs. However, if later you decided to pursue additional graduate study or seek ordination in a different denomination, you may find your degree unacceptable. Second, in the K-12 online learning environment, many students are homeschoolers who are taking selected classes online. In that case, the education is under the homeschooling umbrella and so institutional accreditation is largely moot.