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SEC / FINRA / state securities regulators

US Series 65 and Series 66 route for investment adviser representatives

How Series 65, Series 66, Series 7 pairing, state investment adviser representative rules, and adviser registration facts fit together.

Exam focus

NASAA Series 65 and Series 66 exam-route analysis for investment adviser representative roles.

Who this helps

  • - Investment adviser representative candidates
  • - RIA founders
  • - Hybrid adviser/broker staff
  • - Compliance teams onboarding supervised persons

Route map

  1. 1. Decide whether the person is giving investment advice, acting as an investment adviser representative, selling securities through a broker-dealer, or doing both.
  2. 2. Series 65 is commonly used for investment adviser representative qualification, subject to state rules and exemptions.
  3. 3. Series 66 is commonly used with a valid Series 7 route for combined state securities agent and adviser representative qualification analysis.
  4. 4. Use NASAA exam outlines and the relevant state requirements before choosing a path.

Licensing context

  • - Investment adviser representative status is state-driven and fact-specific.
  • - SEC or state adviser registration for the firm does not automatically settle every individual registration question.
  • - Broker-dealer transaction activity can require separate FINRA registration and exams.

Study focus

  • - Build the adviser vocabulary: fiduciary duties, ethics, portfolio theory, investment vehicles, disclosures, custody, fees, and state securities law.
  • - Understand the difference between advice compensation and transaction compensation.
  • - Study Form ADV, client agreements, brochure disclosure, custody, and solicitor/marketing controls because these appear in real adviser work.

What to verify before relying on the route

  • - The person's office location, client states, advisory role, and state IAR rules.
  • - Whether Series 7 is valid or planned if Series 66 is considered.
  • - Whether professional designations, waivers, or state exemptions apply.

Application tie-in

  • - The adviser compliance file should map representatives to states, client-facing roles, supervision, and disclosure.
  • - Exam choices should follow the firm registration route and state footprint.
  • - IARD/IAPD records and amendments should be checked after filing.

Common mistakes

  • - Assuming Series 65 is always required or always sufficient.
  • - Using Series 66 without understanding the Series 7 pairing.
  • - Ignoring state-specific IAR registration rules.
  • - Confusing adviser representative registration with broker-dealer representative registration.

Paper and module study maps

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.