Series 66 and State-Registered Investment Advisors

🧾 Series 66 and State-Registered Investment Advisers
📘 How the Series 66 Applies to State-Level Registration Requirements

If you plan to operate as an investment adviser representative (IAR) under a state-registered investment adviser (RIA), the Series 66 exam is often a key part of the licensing process. This guide breaks down exactly how the Series 66 fits into the state registration model, who needs it, and what it allows you to do.

🎯 1. What Is the Series 66?

The Series 66 (Uniform Combined State Law Exam) is administered by FINRA on behalf of NASAA (North American Securities Administrators Association). It combines the content of:

• Series 63 (state securities law)
• Series 65 (investment adviser law)

📌 Important: The Series 66 is not a standalone license. You must also pass the Series 7 to become fully registered.

🎯 2. Who Needs the Series 66?

You need the Series 66 if you want to:

• Act as a securities agent (registered rep of a broker-dealer)
• Provide investment advisory services (as an IAR)
• Work for a state-registered RIA or federally covered adviser and serve clients in most U.S. states

✅ If you have passed the Series 7, the Series 66 fulfills your requirement to act as:

• An investment adviser representative (IAR)
• A securities agent under state law

🎯 3. How the Series 66 Applies to State-Registered RIAs

A state-registered investment adviser is an advisory firm that:

• Manages less than $100 million in client assets
• Must register with the state(s) in which it operates or solicits clients

To work as an IAR for such a firm, you must:

• Be registered in the state where your office or clients are located
• Pass the Series 66 and Series 7, or just the Series 65
• File Form U4 via the CRD system and be approved by the state securities regulator

📌 Note: Some states require registration even if you have only one client in the state (unless a de minimis exemption applies—usually 5 clients or fewer).

🎯 4. What If You Don’t Have Series 7?

If you do not hold the Series 7, you cannot take the Series 66. Instead, you should take the Series 65, which:

• Can be taken without sponsorship
• Does not require Series 7
• Qualifies you to act as an IAR under state law

✅ The Series 65 is the better choice if:

• You do not plan to sell securities (no broker-dealer affiliation)
• You’re only focused on fee-based advisory services

🎯 5. State Registration Summary Chart

🎯 6. Continuing Requirements

For IARs of state-registered RIAs:

• Some states have annual continuing education (CE) rules (e.g., under the NASAA IAR CE model rule)
• You must update Form U4 when there are material changes (address, name, outside business activities)

🚀 Conclusion: Series 66 and Your State-Licensed Advisory Role

If you’re pursuing a career as an IAR under a state-registered investment adviser, and you already hold the Series 7, the Series 66 is your path to registration. It simplifies compliance by combining both state law and investment adviser content in one exam.

If you’re not associated with a broker-dealer, or you’re starting from scratch, the Series 65 may be a more direct and flexible choice.

🎓 Want help prepping for the Series 66 or Series 65?
Access targeted study guides, flashcards, and exam simulations at:
👉 https://finra-exam-mastery.com

Choose your path. Prep with purpose. Pass with confidence.