The Series 63 and the Series 65 were developed on an assumption about how financial professionals divide their work. What was that assumption, and how does practice at a major full-service wirehouse depart from it?

They assume a professional enters the industry through advisory work and takes up transaction business later, whereas full-service advisers at wirehouses begin on the transaction side and stay there.

They assume securities transaction business and investment advisory business are carried on by different people, whereas a full-service adviser does both for the same clients.

They assume advisory clients and brokerage customers are served through different kinds of account, whereas a full-service adviser places both kinds of business in one account for each client.

They assume a professional will serve either retail clients or institutional clients, whereas a full-service adviser at a wirehouse builds a single book of business spanning both.

Before the Series 66 existed, a professional who needed both state registrations sat the Series 63 and the Series 65. What was redundant about sitting both of them?

Each examination required its own sponsoring firm, so the candidate needed an offer from a broker-dealer and from an advisory firm before being allowed to sit either one.

Each examination produced a state registration that the other also produced, so one of the two registrations the professional obtained served no purpose at all.

Each examination called for a demonstration of the same fundamental body of state securities law, so the candidate proved that knowledge a second time to no purpose.

Each examination retested the product knowledge already covered by the federal representative examination, so the candidate proved that same material for a third time.

In what respect is the Series 66 lighter than sitting the Series 63 and the Series 65 separately, and in what respect is it not lighter at all?

It is shorter and takes one sitting rather than two, but it covers the same state securities law, ethical obligations and investment analysis knowledge as the two separate examinations.

It is shorter and takes one sitting rather than two, and it also drops the ethical obligations material, which the federal representative examination covers for agents.

It is shorter and takes one sitting rather than two, and it also confines the state securities law material to the provisions that apply to agents and advisers alike.

It takes one sitting rather than two but is longer than either separate examination, and it tests the combined content of both at a greater depth than either reached.

The Series 65 can be paired with state registration alone for a pure investment advisory practice, yet the Series 66 cannot be used for state registration at all without the Series 7. What explains the Series 66's dependence on the Series 7 where the Series 65 has none?

The Series 7 is needed only to supply the product content the Series 66 leaves out, so a candidate who has covered that material independently may register without it.

The Series 66 also registers its holder as a securities agent, and that component requires federal broker-dealer registration as its complement.

A federal qualification sits behind every examination the state administrators develop, and the pure advisory route is a narrow exception granted to advisers who do no transaction business.

The Series 66 reaches two capacities at once, so it is treated as a supervisory-level examination and requires a representative-level federal qualification beneath it.

A Series 66 result has been passed and no Series 7 registration is active. Which of the two state registrations the Series 66 addresses can a state grant on that result?

The investment adviser representative registration, granted on condition that the Series 7 is passed before the holder conducts any transaction business for customers.

The investment adviser representative registration, because that component of the Series 66 corresponds to the Series 65 and carries no federal qualification requirement of its own.

Neither of them: with no active Series 7 the Series 66 result supports no state registration in either capacity.

The securities agent registration, because the agent component is the half of a Series 66 result that a state administrator can act on without a federal filing.

The Series 66's regulatory content area covers federal investment adviser regulation under the Investment Advisers Act of 1940 alongside state securities law under the Uniform Securities Act. Why does a uniform state law examination reach the federal adviser statute?

Because the examination is delivered by the federal self-regulatory organisation, whose own rules carry the adviser statute's requirements through to registered persons.

Because the Uniform Securities Act takes in the federal adviser statute's prohibited practice provisions, so the two frameworks form one body of law for testing purposes.

Because states that accept the Series 66 require an investment adviser representative to register federally as well, so the examination has to cover both registration regimes.

Because the examination qualifies its holder as an investment adviser representative, a capacity the federal adviser framework governs alongside state law.

A professional who has passed both the Series 7 and the Series 66 is being registered in a state where they will conduct business. How are the two state registrations the result produces obtained there?

Through one application in that state, which achieves both statuses rather than being filed separately for each of them.

Through two applications in that state, one for each status, the two registrations being granted under separate provisions of state law.

Through one application for the agent status, the adviser status following automatically once the firm reports the Series 66 result to the state.

Through one application filed with the state for the agent status and one filed federally for the adviser status, which is recorded at the federal level.

Two candidates will each end up registered in a state as both a securities agent and an investment adviser representative. One follows the Series 66 pathway and the other the separate examination pathway. How does the total examination burden differ, and why?

By two examinations, because the Series 66 pathway replaces the Series 63, the Series 65 and the Series 7 alike with one combined examination covering state and federal content.

By one examination, because the Series 7 is required on both pathways and the difference is the single Series 66 against the Series 63 and Series 65 together.

By no examinations at all, because the Series 66 substitutes one longer examination for two shorter ones, so each pathway still runs to three sittings in total.

By one examination, but only where the candidate already holds the Series 63, so that the Series 66 stands in place of the Series 65 alone rather than both of them.

A representative at a broker-dealer will execute securities transactions for customers for commissions and will take on no fee-based advisory work. The firm asks whether to put them through the Series 66 or the Series 63. What should decide it?

Either one, since both produce the agent registration, so the firm should choose on length alone and the Series 66 is the shorter of the two.

The Series 66, because the representative cannot know in advance whether advisory work will arise and a Series 63 result cannot later be extended to cover it.

The Series 63, because the investment advisory content the Series 66 carries exists to produce a registration this representative will not use.

The Series 63, because a representative holding the Series 66 may not conduct commission business while also registered as an investment adviser representative.

A candidate has passed the Series 7 and the Series 66 and joins a firm that is a FINRA member broker-dealer but is not a registered investment adviser. What can that firm obtain for them?

Neither registration, because a firm that is not registered as an investment adviser cannot sponsor a candidate holding a combined examination result.

Both registrations, because a sponsoring firm's own registrations bear on how it supervises the individual rather than on which registrations it may apply for.

Both registrations, because the Series 66 result carries the adviser component within it and the state grants that status on the examination result.

The securities agent registration, the adviser component requiring association with a firm that is itself registered as an investment adviser.

Two candidates each want state registration as both a securities agent and an investment adviser representative. The first has passed the Series 66 and holds no Series 7 registration. The second holds an active Series 7 registration and has passed no state law examination. Which of them can be registered in both capacities on what they now hold?

Neither of them, because dual state registration rests on the two examinations together and neither examination alone satisfies both requirements.

The first, because the Series 66 qualifies its holder in both capacities and the federal qualification is needed only before transaction business begins.

The second, because the federal representative qualification carries both state registrations with it once the sponsoring firm files for them.

Both of them, each being registered in both capacities at once and then given a set period in which to pass the examination they lack.

The Series 66 removed a duplication that the separate Series 63 and Series 65 examinations created. Which professional never faced that duplication, and so gains nothing from its removal?

A full-service adviser at a major wirehouse who executes securities trades for her clients and also manages those same clients' portfolios for an annual fee.

A professional working in a single capacity, who needs just one of the two state registrations and would have had no reason to sit both examinations.

A professional who already holds the Series 7, since the duplication lay between the federal examination and the two state law examinations.

A professional who needs both state registrations but sits the two separate examinations within one week, while the shared material is still fresh in her mind.

A professional has passed the Series 63 and the Series 65 and holds both state registrations. A colleague suggests she also sit the Series 66 to prove a broader command of the regulatory material. What would the Series 66 test that her two examinations did not?

The registration rules peculiar to dual-registered firms, a topic that arises only once both capacities are examined together in one sitting.

State securities law at greater depth, since the combined examination is longer than either separate examination and probes each topic further.

Nothing new, since its content is drawn from the two examinations she has already passed, combined into a single examination.

The ethics of agents and advisers working side by side, a subject the combined examination adds and neither of the two separate ones covers.

A Series 66 candidate asks whether the examination tests what happens to an agent or an adviser representative who violates the securities laws, or just the conduct those laws require and prohibit. What is the answer?

It examines the conduct, penalties being a matter for the state administrator's enforcement staff that a qualification examination for agents and advisers leaves out.

It examines the conduct, the penalty framework being federal law that the Series 7 examines in depth rather than a state law examination of this kind.

It examines both, but the civil penalties without the criminal ones, criminal liability being left to state prosecutors and so falling outside a state law examination.

It examines both, the civil and criminal penalty framework applicable to violations forming part of the same content area as the prohibited practices.

An investment adviser representative is registered on the Series 65 alone and holds no federal qualification. Her firm, which is also a FINRA member broker-dealer, wants her to begin executing securities transactions for her advisory clients. What would register her as a securities agent as well, and why?

A federal qualification such as the Series 7, and the Series 63, the agent registration needing federal broker-dealer registration alongside the state agent examination.

A federal qualification such as the Series 7, and the Series 63, the federal one being needed because her firm is a FINRA member, whatever registration she seeks there.

The Series 66 alone, the combined examination adding the agent registration to her adviser registration without a federal qualification behind it.

No further examination, a firm that is also a FINRA member being able to sponsor her agent registration on her Series 65 result.

Economic factors and business information receive less extensive treatment on the Series 66 than on the Series 65. What accounts for the lighter treatment?

An investment adviser representative makes little use of economic analysis in client work, so the combined examination keeps only a brief introduction to that material.

The state law content of two examinations must fit into one, so every non-regulatory area was cut back in proportion to make room for it.

The economic content was moved into the federal adviser law material, where it is examined as part of the fiduciary framework instead.

A Series 66 holder, acting as an investment adviser representative, recommends a portfolio to an advisory client. What must the recommendation be consistent with?

The suitability standard alone, because a fiduciary duty attaches to the advisory firm and not to its individual representatives.

The firm's approved product list, against which every recommendation a representative makes is measured.

The fiduciary duty that applies to investment adviser representatives.

The best execution standard, because an advisory recommendation is judged by the price obtained when the trade is placed.

The Series 66's regulatory content covers registration requirements and exemptions for investment adviser representatives as well as for broker-dealer agents. Why does it reach both?

Because a broker-dealer agent at a dual-registered firm supervises its adviser representatives and so must know their registration rules.

Because the Series 66 takes the place of the Series 7's regulatory content, which would otherwise have covered the agent's registration rules.

Because an adviser representative must hold agent registration first, so the examination tests the agent's rules as a prerequisite to the adviser's.

Because the examination qualifies its holder in both capacities, so its regulatory content follows both of the registrations it produces.

A professional who holds the Series 7 and the Series 66 is registered in a state as an investment adviser representative. What does that registration authorise her to do?

Solicit and execute securities transactions with customers for commission on behalf of the broker-dealer that employs her.

Supervise the securities agents who execute transactions for the clients of the advisory firm she is associated with.

Provide investment advice to clients for compensation in her own name, without any association with a registered advisory firm.

One representative holds the Series 7 and the Series 63; another holds the Series 7 and the Series 66. How does the state securities agent registration each of them holds compare?

The Series 66 holder's is narrower, confined to securities transactions for the clients of the advisory firm through which she is also registered as an adviser representative.

The Series 66 holder's is broader, extending to the supervision of other agents at the firm, because the combined examination reaches two capacities at once.

It is the same registration, the Series 66's agent registration being equivalent to the one that the Series 63 produces when paired with the Series 7.

The Series 66 holder's is provisional, lapsing if she gives up her adviser representative registration, because the two were granted on one application.

A professional has passed the Series 66 and holds an active Series 7 registration. Where does that combination produce state registration as a securities agent and as an investment adviser representative?

In every state, the combined examination being recognised in all jurisdictions as a uniform national qualification.

Only in the state where she sat the examination, other states requiring their own state law examination of her.

Only in states that have adopted NASAA's designation waiver model rule for adviser representatives.

A representative is already registered as a securities agent on the Series 7 and the Series 63 and holds no professional designation. She now needs investment adviser representative registration as well, and can sit either the Series 65 or the Series 66 to obtain it. How does that choice bear on her total examination burden?

It makes no difference, either choice being one further examination, so the combined examination saves her nothing at this stage.

The Series 66 saves her one examination, since it stands in for the Series 63 she has passed as well as for the Series 65.

The Series 66 adds one examination to her burden, since it has to be sat together with a fresh sitting of the Series 7.

The Series 65 saves her one examination, since choosing the Series 66 would mean sitting the Series 63 content again within it.

A representative holding the Series 7 joins a firm that is both a FINRA member broker-dealer and a registered investment adviser. She will execute securities transactions for customers and give no fee-based advice. What should decide whether she sits the Series 63 or the Series 66, and with what result?

The registrations her firm holds, which cover the broker-dealer and the adviser capacities, so the Series 66.

The registrations she will herself use, here the agent registration without the adviser one, so the Series 63.

Her firm's supervisory arrangements, a representative at a dual-registered firm being supervised in both capacities, so the Series 66.

The commission basis of her pay, a representative paid by commission being barred from also holding adviser registration, so the Series 63.

The Series 66 requires a slightly higher passing score than the Series 63 and the Series 65 each require on their own. What does the higher score reflect?

A condition NASAA attached when the industry asked for a combined examination, the higher score being the price of letting a single sitting replace the two separate ones.

The precision that state securities law demands, a higher score being set because the combined examination tests the Uniform Securities Act together with its NASAA amendments.

The combined nature of the examination, and the breadth of regulatory knowledge needed to work competently both as an agent and as an adviser representative.

The adviser representative registration it leads to, a higher score being set for every examination through which that registration can be obtained in any of the states.

In a state that requires the Series 63 and allows the designation waiver, a Certified Financial Planner who has passed the Series 7 seeks the two registrations the Series 66 produces. How does her designation bear on them?

It can answer the adviser representative examination requirement and the agent one as well, the waiver covering the combined content.

It can answer the adviser representative examination requirement, and her Series 7 then answers the agent requirement with no state examination.

It answers neither requirement there, the waiver being closed to a candidate who has passed the Series 7 and so could sit the Series 66.

It can answer the adviser representative examination requirement, but the agent registration still requires its examination.

A Chartered Financial Analyst had her designation accepted in place of the adviser representative examination in the state where she first registered. She now plans to advise clients from an office in another state as well. How does the earlier acceptance bear on her position in that other state?

It does not settle it, since waiver rules vary by state and she must verify that other state's own rules before relying on it.

It settles it, because a waiver granted in one state is recognised by every other state that has adopted NASAA's uniform model rule.

It settles it once she files the earlier waiver decision with that other state's administrator before she begins advising any of her clients there.

It rules the waiver out in that other state, a designation waiver being usable only in the state where its holder first registers.

A Certified Financial Planner has had her designation accepted in place of the examination for investment adviser representative registration. She joins a firm that is a FINRA member broker-dealer but is not a registered investment adviser. Can she be registered as an investment adviser representative through that firm?

Yes, the designation itself standing in for the firm's adviser registration, which is why holders of the designation may advise independently.

No, the designation answers the examination requirement, and the registration still requires association with a registered investment advisory firm.

Yes, a FINRA member broker-dealer being able to sponsor any state registration for which its associated person is qualified.

No, a designation holder being registrable as an adviser representative only after first holding a securities agent registration.

A recent graduate who has never worked in the securities industry and has not taken the SIE wants to register for and sit the Series 66. What must she have first?

A passing SIE result, the foundational examination being required before any state law examination can be scheduled.

Association with a registered investment advisory firm, which must sponsor any candidate sitting an examination with adviser content.

Nothing of that kind, since any individual may sit it without the SIE and without being associated with any firm.

Association with a FINRA member firm, which must open a testing window for her by filing a Form U4 on her behalf.

Why is the Series 66 particularly common among professionals at firms that are both FINRA member broker-dealers and registered investment advisers?

Because professionals at such firms may use the Series 66 without the Series 7, the firm's adviser registration standing in for it.

Because a state grants adviser representative registration automatically to any agent whose firm is also a registered investment adviser.

Because the Series 66 is the only examination through which a professional at such a firm can obtain adviser representative registration.

Because one such firm can provide the sponsorship that each of the two registration components requires, so both can proceed together.

Series 66 — The Combined State Law Exam Explained

Series 66

The Series 66 — formally titled the Uniform Combined State Law Examination — is the NASAA-developed, FINRA-administered licensing examination that qualifies individuals as both state-registered securities agents and state-registered investment adviser representatives in a single examination, combining the content and registration outcomes of the Series 63 and Series 65 into one unified assessment.

The Series 66 was developed by the North American Securities Administrators Association at industry request to serve the growing population of securities industry professionals who function in both capacities simultaneously — conducting securities transactions for customers as broker-dealer agents while also providing investment advice to those same clients for compensation as investment adviser representatives.

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.