Series 66

The Series 66 may only be used to satisfy state registration requirements when paired with the Series 7 General Securities Representative examination — the Series 7 is a corequisite for the Series 66, and neither examination alone satisfies both registration requirements. The Series 66 is tested on the SIE and Series 7 examinations in the context of the state registration framework and the comparison of available examination pathways.

The Purpose — Eliminating Duplicate Examination Burden

The financial services industry has evolved significantly since the separate Series 63 and Series 65 examinations were developed — the clean separation between broker-dealer agent activities and investment advisory activities that those examinations presuppose does not reflect the reality of how most full-service financial professionals conduct their practices today.

A full-service financial adviser at a major wirehouse — a firm such as Morgan Stanley, Merrill Lynch, UBS, or Wells Fargo Advisors — typically holds registration as a broker-dealer agent, executing securities transactions for clients — and simultaneously operates as an investment adviser representative, providing fee-based investment planning and portfolio management services to those same clients. 

This dual-capacity professional needs both the Series 63 state registration as a securities agent and the Series 65 state registration as an investment adviser representative — but requiring them to sit for two separate state law examinations to demonstrate knowledge of the same fundamental body of state securities law created unnecessary redundancy.

NASAA developed the Series 66 to eliminate this duplication — combining the content of the Series 63 and Series 65 into a single examination that, when paired with the Series 7, achieves both state registrations simultaneously. 

The Series 66 is somewhat shorter and is sometimes described informally as more efficient than taking the Series 63 and Series 65 separately — though the examination is not meaningfully easier in its regulatory content, covering the same body of state securities law, ethical obligations, and investment analysis knowledge that the individual examinations address.

The Corequisite Requirement — The Series 7 Linkage

The most critical structural feature of the Series 66 — and the most directly tested aspect of Series 66 eligibility on securities licensing examinations — is that the Series 7 General Securities Representative examination is a mandatory corequisite. 

A candidate who passes the Series 66 but does not hold an active Series 7 registration cannot register with any state as either a securities agent or an investment adviser representative based on the Series 66 result — the Series 66 alone is insufficient for either state registration without the accompanying federal FINRA qualification.

This corequisite structure reflects the dual nature of what the Series 66 registration accomplishes. The securities agent registration component — which corresponds to the Series 63 — requires federal FINRA broker-dealer registration as its complement. 

The investment adviser representative registration component — which corresponds to the Series 65 — does not independently require the Series 7, since the Series 65 can be paired with state registration alone for pure investment advisory practice. But the Series 66, by definition, registers the holder as both a securities agent and an investment adviser representative — and the securities agent component requires FINRA broker-dealer registration, which in most cases means the Series 7.

Candidates may take the Series 66 and the Series 7 in either order — neither is a prerequisite for the other in the sense of needing to pass one before sitting for the other. Both must be passed and both registrations must be completed before the candidate can register with a state. 

A candidate who has passed the Series 66 but not yet passed the Series 7 has a valid Series 66 result but cannot achieve state registration until the Series 7 is also passed and firm association and sponsorship are established.

The Examination Format and Content

The Series 66 examination consists of one hundred scored multiple-choice questions and ten unscored pretest questions — one hundred and ten questions total — administered over one hundred and fifty minutes — two and a half hours. 

The passing score is seventy-three percent — seventy-three correct answers out of one hundred scored questions. The passing score of seventy-three percent — slightly higher than the seventy-two percent required for the Series 63 and Series 65 individually — reflects the combined nature of the examination and the comprehensive regulatory knowledge required to function competently as both a broker-dealer agent and an investment adviser representative.

NASAA updated the Series 66 test specifications alongside the Series 65 update effective June 12, 2023, restructuring the content areas to reflect the current regulatory and professional environment.

Economic Factors and Business Information accounts for approximately ten percent of the examination — covering macroeconomic concepts, business cycle analysis, interest rate analysis, monetary and fiscal policy, and the economic indicators that investment professionals use in investment analysis and client recommendations. 

This section is less extensive in the Series 66 than in the Series 65 alone — the Series 66 presupposes that candidates have already passed the Series 7, which covers substantive economic and market content, so the Series 66 does not repeat that content in depth.

Investment Vehicle Characteristics accounts for approximately twenty-five percent of the examination — covering the essential characteristics, risks, and regulatory framework applicable to the investment products that investment professionals recommend and execute for clients, including equities, fixed income, mutual funds, exchange-traded funds, retirement accounts, variable products, and alternative investments. Knowledge of these products from a recommendation and advisory perspective is the foundation for the Client Recommendations and Strategies content that follows.

Client Investment Recommendations and Strategies accounts for approximately thirty percent of the examination — the applied advisory core of the Series 66 that tests candidates' ability to assess client investment profiles, identify appropriate investment strategies, construct suitable portfolios, and make recommendations consistent with the fiduciary duty applicable to investment adviser representatives. This section specifically tests the integration of product knowledge with client profiling skills — requiring candidates to match investment solutions to client circumstances rather than simply identifying product characteristics in isolation.

Laws, Regulations, and Guidelines Including Prohibition on Unethical Business Practices accounts for approximately thirty-five percent of the examination — the regulatory compliance foundation covering state securities law under the Uniform Securities Act with NASAA amendments, federal investment adviser regulatory content under the Investment Advisers Act of 1940, the fiduciary duty framework, prohibited practices under state and federal law, recordkeeping and disclosure obligations, registration requirements and exemptions for broker-dealer agents and investment adviser representatives, and the civil and criminal penalty framework applicable to violations.

What the Series 66 Achieves — The Registration Outcome

A candidate who passes the Series 66 and holds an active Series 7 registration achieves the following state registrations in states that accept the Series 66.

State registration as a securities agent — equivalent to the registration that passing the Series 63 achieves for candidates paired with the Series 7. This registration authorises the individual to function as a broker-dealer agent — soliciting and executing securities transactions with customers — in compliance with state securities laws.

State registration as an investment adviser representative — equivalent to the registration that passing the Series 65 achieves as a standalone. This registration authorises the individual to provide investment advice to clients for compensation on behalf of a registered investment advisory firm — in compliance with state investment adviser representative registration requirements.

Both registrations are obtained through a single state application — the candidate who has passed both the Series 7 and the Series 66 applies for registration in each state where they will conduct business, and the single application achieves dual registration as both a securities agent and an investment adviser representative without separate applications for each status.

The Series 66 Versus the Separate Examination Pathway

Financial professionals and their employers face a practical choice between two examination pathways to achieve dual state registration as both a securities agent and an investment adviser representative — the single Series 66 examination or the two separate examinations, Series 63 plus Series 65.

The single Series 66 examination pathway involves passing the Series 7 — already required in either pathway for broker-dealer agent registration — and passing the Series 66 — one examination covering combined content. The total examination burden is two examinations — Series 7 and Series 66.

The separate examination pathway involves passing the Series 7 for federal broker-dealer registration, plus passing the Series 63 for state securities agent registration, plus passing the Series 65 for state investment adviser representative registration. The total examination burden is three examinations — Series 7, Series 63, and Series 65.

For candidates who will need both state registrations simultaneously — as is the case for most full-service financial professionals at dual-registered broker-dealer and investment advisory firms — the Series 66 pathway reduces the examination burden by one examination. For candidates who need only securities agent state registration — those who conduct only broker-dealer business with no fee-based advisory component — the Series 63 alone paired with the Series 7 is the appropriate and more targeted pathway, without the need to cover the additional investment advisory content of the Series 65 or Series 66.

Professional Designation Waivers

NASAA's model rule allowing certain professional designations to substitute for the examination requirement applies to the Series 65 component of the Series 66's registration outcomes. Holders of the CFA, CFP, ChFC, CIC, or PFS designations who have already passed the Series 7 may in some states be able to satisfy the investment adviser representative registration requirement through their designation without separately passing the Series 66 or Series 65 — though the securities agent registration component — equivalent to the Series 63 — still requires the examination in states that require the Series 63. The specific waiver rules vary by state and candidates should verify the rules applicable to the states where they intend to conduct business.

Eligibility — The No-Prerequisite Structure

Like the Series 63 and Series 65, the Series 66 does not require passage of the SIE examination as a prerequisite and does not require firm sponsorship to sit for the examination. Any individual may register for and sit for the Series 66 without being associated with a FINRA member or registered investment advisory firm. This open access structure allows candidates to take the Series 66 before or simultaneously with the Series 7 — in whatever sequence best fits their preparation schedule and career timeline — since neither the Series 7 nor the Series 66 is a prerequisite for the other in the examination scheduling sense.

State registration following passage requires firm sponsorship — the candidate must be associated with and sponsored by a FINRA member firm that submits the registration application for the broker-dealer agent component, and must be associated with and registered through a registered investment advisory firm that submits the IAR registration application for the investment adviser representative component. A dual-registered firm — one that is both a FINRA member broker-dealer and a registered investment adviser — can submit both registration applications simultaneously, which is why the Series 66 is particularly common among professionals at dual-registered firms where broker-dealer and investment advisory services are offered through the same corporate entity.

NASAA's Exam Validity Extension Program model rules for both the Series 63 and Series 65 components apply to the Series 66 — the Series 66 result contains both a Series 63 credit and a Series 65 credit, and the extension programme for each component can be maintained independently through the applicable annual continuing education requirements in states that have adopted the model rules.

Examination Relevance and Key Takeaways

The Series 66 is tested on the SIE and Series 7 examinations in the context of the state registration framework, the available examination pathways for dual state registration, and the corequisite relationship between the Series 66 and the Series 7.

The key points to retain are these.

The Series 66 — Uniform Combined State Law Examination — is developed by NASAA and administered by FINRA, qualifying individuals simultaneously as state-registered securities agents and state-registered investment adviser representatives — combining the registration outcomes of the Series 63 and Series 65 into a single examination. The Series 7 is a mandatory corequisite — the Series 66 result alone does not achieve either state registration without a simultaneously active Series 7 registration. The examination consists of one hundred scored questions and ten unscored pretest questions over one hundred and fifty minutes — passing score is seventy-three percent, seventy-three correct answers out of one hundred scored. The four content areas — updated June 12, 2023 — are Economic Factors and Business Information at approximately ten percent, Investment Vehicle Characteristics at approximately twenty-five percent, Client Investment Recommendations and Strategies at approximately thirty percent, and Laws Regulations and Guidelines at approximately thirty-five percent.

The Series 66 pathway — Series 7 plus Series 66 — achieves dual state registration in two examinations versus the alternative pathway of Series 7 plus Series 63 plus Series 65 in three examinations. Neither approach is universally superior — the Series 66 is more efficient for candidates who need both state registrations, while separate Series 63 registration is more targeted for candidates who need only securities agent state registration without the investment adviser representative component. No firm sponsorship or SIE passage is required to sit for the Series 66 — but state registration following passage requires firm association and sponsorship from both a FINRA member broker-dealer for the agent registration and a registered investment adviser for the IAR registration.