In the world of financial services, the learning curve often feels more like a vertical wall. Just when you think you’ve conquered the major hurdles—like the Securities Industry Essentials (SIE) and the formidable Series 7—you are presented with a new alphabet soup of requirements.
Suddenly, you aren't just hearing about FINRA; you're hearing about NASAA. You aren't just worried about federal laws; you need to worry about "Blue Sky" laws. And the most common question that arises for new financial professionals is: Which of the state securities exams do I actually need?
The confusion is understandable. The Series 63, Series 65, and Series 66 exams all sound similar. They cover overlapping material. They are all administered by the North American Securities Administrators Association (NASAA). Yet, each one serves a distinct legal purpose and unlocks specific career capabilities. Choosing the wrong one can mean wasted study time, delayed registration, and a headache you didn't need.
This comprehensive guide will break down the differences between the Series 63, Series 65, and Series 66. We will explore who needs which license, how the exams differ in difficulty, and how to determine the right path for your specific career goals in the financial industry.
Before diving into the specific exams, it is crucial to understand why they exist. Most people are familiar with FINRA (Financial Industry Regulatory Authority), which oversees broker-dealers on a federal level. However, the United States has a dual regulatory system.
While the SEC and FINRA regulate the industry nationally, each individual state has its own set of securities regulations, widely known as "Blue Sky Laws." These laws are designed to protect investors from fraud at the local level.
This is where NASAA comes in. The NASAA exams (Series 63, 65, and 66) ensure that financial professionals understand these state-specific regulations. Unlike FINRA exams (like the Series 6 or 7), which focus heavily on products and federal rules, NASAA exams focus heavily on ethics, state registration requirements, and the legal definitions of who is an "agent" versus an "investment adviser."
While a FINRA license (like the Series 7) might authorize you to sell a stock, it doesn't necessarily authorize you to do business with a resident of California or New York. For that, you need a state license.
The Series 63 is the grandfather of state exams. It is the most common, the shortest, and for many, the first encounter with state regulations.
The Series 63 is strictly a state law exam. It is designed to qualify candidates as securities agents. The term "agent" here is specific—it generally refers to an individual who represents a broker-dealer in effecting securities transactions.
If you have a Series 6 or Series 7 license, you are federally qualified to sell securities. However, to actually solicit business from a client in a specific state, that state requires you to show you understand their laws. The Series 63 satisfies this requirement for nearly every state.
You typically need the Series 63 if:
Think of the Series 63 as the "sidecar" to your FINRA license. It validates your ability to operate legally within state lines.
The content is almost entirely focused on the Uniform Securities Act (USA). This is a model law that many states use as a template.
Because it is short and focused only on regulation (no math, no product knowledge), many candidates underestimate it. However, the legal language can be tricky. If you need to prepare, finding the rightSeries 63 licensing courses is essential to navigating the "legalese" of the exam.
The Series 65 is a different beast entirely. While the Series 63 is for agents (salespeople), the Series 65 is for advisers (advice-givers).
The Series 65 qualifies an individual to act as an Investment Adviser Representative (IAR). This is a critical distinction in the financial world.
If you want to charge clients for financial advice or manage portfolios for a fee, you are operating as an investment adviser, and the Series 65 is the license that governs that activity.
You typically need the Series 65 if:
Interestingly, you do not need a sponsor to take the Series 65. This makes it popular among career changers or independent financial planners who are setting up their own shops without affiliation to a large broker-dealer.
The Series 65 is much broader than the Series 63. It covers state laws, but it also functions as a competency exam for general financial knowledge.
Because it covers product knowledge and economics, it is significantly harder and longer than the Series 63. For those pursuing this path, comprehensiveSeries 65 training is vital to mastering the diverse curriculum.
If the Series 63 and Series 65 had a baby, it would be the Series 66. This exam was created to streamline the process for individuals who need both licenses.
The Series 66 essentially combines the content of the Series 63 and the Series 65 into one exam—but with a major catch. It is only valid if you also hold a Series 7 license.
The Series 66 qualifies you as both a securities agent (Series 63 equivalent) and an Investment Adviser Representative (Series 65 equivalent). It allows you to wear both hats: you can earn commissions on trades and charge fees for advice.
The Series 66 is the standard for "dual-registered" professionals. You typically take it if:
The Series 66 assumes you already know product knowledge because you have the Series 7. Therefore, it strips out the intense product sections found in the Series 65 (like what a stock is or how a bond works) and focuses heavily on compliance, ethics, and regulations.
If you are on the Series 7 track, theSeries 66 exam is often the preferred route because it avoids taking two separate state exams (63 and 65).
To make this easier to digest, let's look at the key differences side-by-side.
|
Feature |
Series 63 |
Series 65 |
Series 66 |
|
Role |
Securities Agent |
Investment Adviser Rep (IAR) |
Agent + IAR |
|
Primary Focus |
Selling / Commissions |
Advice / Fees |
Selling + Advice |
|
Content |
State Laws (USA) only |
Laws + Products + Economics |
Laws + Advice (No products) |
|
Prerequisites |
None (usually paired with S6/S7) |
None |
Must hold Series 7 |
|
Question Count |
60 |
130 |
100 |
|
Time Limit |
75 Minutes |
180 Minutes |
150 Minutes |
|
Difficulty |
Low/Moderate |
High |
High |
|
Best For |
Brokers, Insurance Agents (w/ S6) |
Financial Planners, RIAs |
Full-Service Financial Advisors |
Choosing the right exam depends entirely on your career path and existing credentials. Here are a few common scenarios to help you decide.
For a broader look at how these fit into the big picture, check out our hub onsecurities licensing.
While difficulty is subjective, most industry professionals rank the exams as follows:
Regardless of which exam you choose, the study strategy for state securities exams differs from FINRA exams. Here is how to tackle them.
The Uniform Securities Act (USA) is built on definitions. You need to know exactly who qualifies as a "Broker-Dealer," an "Agent," an "Investment Adviser," and an "Investment Adviser Representative."
A huge portion of these exams focuses on when you don't have to register.
NASAA questions are famous for their "double negatives" and "except" questions.
Especially for the Series 65 and 66, you must distinguish between federal law (Investment Advisers Act of 1940) and state law (Uniform Securities Act). The rules for record-keeping, brochures, and contracts differ slightly. You need to know which rule applies to which type of adviser.
Fact: While it covers the privileges of both, it does not cover the content of both equally. The Series 66 removes the product knowledge found in the Series 65 because it assumes you know it from the Series 7. If you took the Series 7 years ago and have forgotten the basics, the Series 66 can be surprisingly difficult because it assumes that foundational knowledge is fresh.
Fact: Many smart people fail the Series 63 because they treat it as an afterthought. The pass score is relatively high (roughly 72%), and the questions are dry and technical. Give it at least 1-2 weeks of dedicated study.
Fact: No college degree is required for any of these exams. The Series 65 does not even require a sponsor, meaning anyone can pay the fee and sit for the exam.
One nuance to keep in mind is license validity. Once you pass the Series 63, 65, or 66, you have two years to register with a firm. If you leave the industry, your license remains valid for two years before expiring.
However, NASAA recently adopted a model rule for an Exam Validity Extension Program (similar to FINRA's MQP), which may allow eligible individuals to maintain their qualification for up to five years through continuing education. Always check the specific rules of the state where you are registering, as adoption of this rule varies.
Choosing between the Series 63, 65, and 66 is rarely a matter of preference; it is usually a matter of requirement.
These exams are the gatekeepers to doing business legally. They ensure you understand the rules of the road so you can protect your clients and your career. While the material can be dry, mastering it is the mark of a competent professional.
Don't let the "Blue Sky" laws cloud your career path. Identify the license that fits your business model, grab high-quality study materials, and knock it out.
Ready to start studying?
The sooner you pass, the sooner you can focus on what matters most: helping your clients achieve their financial goals.
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