Examination Requirements

Passing a qualifying exam is a prerequisite to registering as an investment adviser representative (IAR), but passing alone does not make someone an IAR. The applicant must still register through an investment adviser firm.

Which Exams Qualify an Applicant?

Under the NASAA Model Rule on IAR qualifications, an IAR applicant must pass one of the following (unless waived):

• The Series 65 (Uniform Investment Adviser Law Examination), passed within 2 years of the application date, alone, or
• The Series 66 (Uniform Combined State Law Examination) and the Series 7, each passed within 2 years of the application date, plus the SIE, passed within 4 years of the application date

The Series 66 alone is not sufficient; it must be paired with the Series 7. The Series 66 is treated as equivalent to having already passed both the Series 63 and the Series 65.

Which Professional Designations Waive the Exam?

Holding one of five qualifying professional designations, current and in good standing, waives compliance with the entire examination requirement above (not just the Series 65 alone; the waiver covers whichever pathway would otherwise apply):

• CFP (Certified Financial Planner)
• ChFC (Chartered Financial Consultant)
• PFS (Personal Financial Specialist)
• CFA (Chartered Financial Analyst)
• CIMA (Certified Investment Management Analyst)

A CPA (Certified Public Accountant) license alone does not waive the exam; the holder must also carry the PFS designation.

The list is five, and it is closed. If you see CIC (Chartered Investment Counselor) on a waiver list in older study material, that list is out of date: NASAA replaced CIC with CIMA in May 2024, and the CIC program was discontinued in 2025.

Exam Tip: Gotchas

• Passing the Series 65 does NOT by itself make a person an IAR. The exam is only a prerequisite; the person must still apply for registration through an investment adviser firm.
• A qualifying designation waives the whole exam requirement, not one narrow exam. The NASAA rule waives compliance with the exam section as a whole, so a current CFP, for example, needs no qualifying exam at all, not merely a Series 65 substitute.

How Long Does a Passing Exam Score Stay Valid?

An exam stays valid while the person stays continuously registered as an IAR. The 2-year clock only starts running once that registration ends.

• An individual registered as an IAR in any state within the past 2 years does not have to retake the exams to register again. This protects IARs who change firms or move between states.
• If the individual has been unregistered for more than 2 years, the exams must be retaken, unless the FINRA Maintaining Qualifications Program applies.

What Is the FINRA Maintaining Qualifications Program?

An individual who is unregistered as an IAR for more than 2 but fewer than 5 years may keep FINRA qualifying exams (Series 7, SIE) valid by participating in FINRA's Maintaining Qualifications Program.

Exam Tip: Gotchas

The Maintaining Qualifications Program does NOT extend the Series 65 or Series 66. Those are NASAA exams, not FINRA exams, so the program only preserves the FINRA-administered pieces (Series 7, SIE) of the Series 66 + Series 7 pathway.

What Authority Does the Administrator Have Over Exams?

The Administrator may by rule provide for examinations, written or oral or both, to be taken by any class of or all applicants, and may by rule or order waive the exam requirement for a person or class of persons if the Administrator determines the exam is not necessary for the protection of advisory clients. This authority goes beyond the Model Rule's five enumerated designation waivers.

What Should You Check on Exam Day?

• Series 65 within 2 years, or Series 66 plus Series 7 each within 2 years plus the SIE within 4 years; Series 66 alone never satisfies the requirement
• Only five designations waive the exam (CFP, ChFC, CFA, PFS, CIMA), and only if current and in good standing at the time of filing; the waiver covers the whole exam requirement, not just the Series 65
• Re-registering within 2 years of a prior IAR registration skips the exam; beyond 2 years the exams are due again unless the FINRA Maintaining Qualifications Program covers the FINRA-administered pieces
• The Maintaining Qualifications Program never extends the Series 65 or Series 66
• The Administrator's own general waiver authority is broader than the Model Rule's five listed designations