Series 63 vs. 65 vs. 66 Exams: Key Differences

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The Series 63, 65 and 66 are all state law exams written by the North American Securities Administrators Association (NASAA). They qualify different roles. The Series 63 qualifies you to act as a securities agent, someone who buys and sells securities for clients, under state law. The Series 65 qualifies you to act as an investment adviser representative (IAR) who gives investment advice for a fee. The Series 66 combines the state law content of the 63 with the advisory law of the 65, so a single exam covers both roles. It assumes you also hold the FINRA Series 7, which is its corequisite.

Choosing among them comes down to two questions: whether you will sell securities, give paid advice, or both, and whether you have passed (or will pass) the Series 7.

Which Exam Fits Which Role

Each state’s securities administrator sets the actual registration requirements, and the firm sponsoring your registration will tell you which exams it needs you to hold.

Understanding the Series 63

The Series 63’s formal name is the Uniform Securities Agent State Law Examination. In most states, a new registered representative must pass it, or an exam that includes its content such as the Series 66, to register. FINRA exams like the Series 7 qualify someone under industry rules; the Series 63 covers the separate layer of state law that governs who may sell securities in a given state.

The exam has these features:

• 65 questions in total, 60 of them scored. The other five are unmarked pretest questions being evaluated for future exams. They can appear anywhere, so answer every question as if it is scored.
• 75-minute time limit.
• Passing score of 72%, which means 43 of the 60 scored questions answered correctly.
• Fee of $147, as listed by FINRA. NASAA sets these fees and can change them.

The content centers on state securities regulation: registration of agents, broker-dealers, investment advisers and securities under the Uniform Securities Act, the state administrator’s powers, and ethical practices and prohibited conduct with clients. NASAA’s content outline is the authoritative description of what is tested and how heavily each topic is weighted.

The Series 63 does not test product knowledge. It assumes you will learn about stocks, bonds, options and funds through the Series 7 (or the narrower Series 6). It also does not qualify you to give advice for a fee, which is the job of the Series 65 or 66.

NASAA has allowed candidates to take qualification exams remotely on their own camera-equipped computers as well as at testing centers.

Overview of the Series 65

The Uniform Investment Adviser Law Examination, or Series 65, was NASAA’s first exam for people who want to provide fee-based investment advisory services. It began with 75 questions focused mostly on the Uniform Securities Act, NASAA amendments and ethics, and has since grown into a much broader competency exam.

Its current structure:

• 140 questions in total, 130 scored, with 10 unscored pretest questions mixed in.
• 180-minute time limit, the longest of the three exams.
• Passing score of 72%, or 94 of 130 scored questions correct.
• Fee of $187.
• No prerequisite or corequisite.

The Series 65 includes the law and ethics found on the other state exams, plus economic factors and business information, investment vehicle characteristics, client investment recommendations and strategies, and analysis. Because there is no Series 7 to fill gaps, the exam must confirm that an adviser understands the products and methods behind the advice.

Many Series 65 candidates come from neighboring fields, such as an accountant adding fee-only investment advice to a practice or a planner joining a registered investment advisory firm as an IAR. Securities professionals already on the Series 7 track usually take the Series 66 instead.

All About the Series 66

The Uniform Combined State Law Examination, or Series 66, merges the Series 63 and Series 65. More precisely, it merges their law and ethics content. It leaves out most of the product, analysis and strategy questions that make up a large share of the Series 65, on the assumption that the candidate gets that knowledge from the Series 7.

Its structure:

• 110 questions in total, 100 scored, with 10 unscored pretest questions.
• 150-minute time limit.
• Passing score of 73%, or 73 of 100 scored questions correct. The required percentage is one point higher than on the 63 and 65.
• Fee of $177.
• No prerequisite, but the Series 7 is a corequisite.

The corequisite affects the order in which you can plan exams. You may sit for the Series 66 without having passed the Series 7. Either exam can come first. However, you cannot register in your state as an agent and IAR on the strength of the Series 66 until you have passed both. Passing the 66 alone does not make you an investment adviser representative.

When NASAA built the Series 66, a committee of securities industry experts removed subject matter duplicated in the Series 7, which is why it is shorter than the Series 65.

Exam fees must be paid before you sit for the test. If you are joining a broker-dealer or advisory firm, the employer often pays them, along with study materials, as part of the registration process.

Exam Comparison

Fees are as listed in the exam outlines and may be revised.

Can You Take the Series 66 Instead of the Series 63?

Yes. The Series 66 contains the agent state law material the Series 63 tests, so a candidate who passes the 66 and the Series 7 does not normally need to pass the 63 separately to register as an agent. In that sense, a Series 66 “covers” a 63. The two are not the same exam, though. The 66 adds investment adviser law and is longer, with 100 scored questions against 60.

You cannot register on the basis of the Series 66 without the Series 7, because of the corequisite. Someone who wants advisory registration without the Series 7 should take the Series 65.

Some practical consequences follow from this:

• If you only plan to sell securities, the Series 66 is more exam than you need. The 63 is shorter and cheaper.
• If you plan to sell and advise and already have the Series 7, the 66 replaces two exams (63 and 65) with one, at one exam fee rather than two.
• If you plan to advise only and have no Series 7, the 66 does not help on its own. The Series 65 is the exam built for you.

How These Exams Fit With the SIE, Series 6 and Series 7

The state exams sit on top of FINRA’s qualification exams. FINRA’s exams cover products, markets and industry rules. The NASAA exams cover state law and, for the Series 65, advisory knowledge.

• SIE (Securities Industry Essentials): an entry-level FINRA exam on basic market knowledge. It is a corequisite for representative-level exams such as the Series 7 and Series 6. The SIE does not replace any of the state exams.
• Series 6: a FINRA exam for limited representatives who sell packaged products such as mutual funds and variable annuities. Series 6 holders typically pair it with the Series 63 for state registration.
• Series 7: the General Securities Representative exam. It qualifies a person to sell a broad range of securities, including stocks, bonds and options, usually earning commissions. It pairs with the 63 for agent registration or with the 66 for agent and IAR registration.

The Series 65 vs. Series 7 distinction causes the most confusion. The Series 65 permits fee-based advice, not selling packaged products or executing securities transactions for commissions through a broker-dealer. That requires the Series 7 (or Series 6 for the narrower product set) plus state agent registration. Many advisers hold both, which is why the 7 + 66 combination exists.

Credentials such as the Certified Financial Planner designation or the Chartered Financial Analyst charter are professional certifications, not regulatory qualification exams. They can strengthen a résumé, and some states accept certain designations in place of the Series 65 for IAR registration. Check with the relevant state securities regulator before relying on that.

Investment Adviser Representatives and State Registration

An investment adviser representative (IAR) is an individual employed by an investment adviser who makes recommendations or otherwise gives investment advice to clients. The IAR’s relationship to the advisory firm mirrors that of an agent to a broker-dealer: the firm registers as the business, and the individual registers as the person acting on its behalf.

Registration is split between federal and state authorities. Under the National Securities Markets Improvement Act of 1996 (NSMIA), larger advisers register with the U.S. Securities and Exchange Commission and are known as federally covered advisers. Smaller advisers register with the states. NASAA’s 1997 memorandum of understanding on investment advisers and their representatives sets out how this division works. If an adviser is registered with the SEC, states may not require registration, licensing or qualification of the firm or its supervised persons. There is one exception: states may still license, register or otherwise qualify IARs who have a place of business in that state.

That exception is why an IAR of an SEC-registered firm still takes a state exam: the representative typically needs the Series 65, or the Series 66 with the Series 7, to qualify in their home state before giving clients any advice. Firms must make sure their IARs are registered correctly, and lapses can bring regulatory penalties.

Who Writes and Administers the Exams

NASAA writes all three exams. FINRA, formerly the National Association of Securities Dealers (NASD), administers them under contract. That split explains why you schedule through FINRA but study from NASAA content outlines.

NASAA is an association of state securities administrators. “Administrator” is the generic term for the official who enforces the Uniform Securities Act in a state, whatever the local title. The Series 63 and 66 test heavily on the administrator’s powers: granting, denying, suspending and revoking registrations, issuing orders, and investigating violations.

NASAA was formed in Kansas in 1919, before the Securities Act of 1933 and the Securities Exchange Act of 1934, and drafted model laws for states to adopt. State securities laws are called blue sky laws, after a Kansas Supreme Court justice complained that promoters sold schemes with no more substance than “so many feet of blue sky.” The Uniform Securities Act is the model at the center of all three exams.

Study Time and Difficulty

Study needs differ by candidate. Prep providers commonly recommend about 30 to 50 hours for the Series 63 and 80 to 100 hours for the Series 65 or 66, reflecting their greater length.

The structure indicates the workload. The Series 63 is the narrowest, limited to state law and ethics for agents. The Series 66 is shorter than the 65, but candidates often take it alongside or right after the Series 7, which adds to the total study load. The Series 65 is the broadest: for someone without a Series 7 background, its economics, investment vehicles, portfolio strategy and analysis content is where most of the extra study time goes.

The state exams are narrower than the Series 7, which covers a wide range of products and trading rules. A candidate strong in markets but new to regulatory language may still find the law-heavy 63 and 66 demanding.

Career Paths and Pay

The exams you pass determine the roles you can hold. Employers include broker-dealers, banks, insurance companies, investment advisory firms and large corporations.

• Series 63 (with Series 6 or 7): financial advisor, financial broker, insurance agent selling securities products, and other roles that involve buying and selling securities for clients in exchange for commissions.
• Series 65: financial advisor, investment consultant, compliance officer, securities instructor, and other roles centered on paid investment advice.
• Series 66 (with Series 7): financial advisor, retirement account advisor, wealth management associate, sales manager, risk management officer, and other roles that combine trading securities with fee-based advice.

The U.S. Bureau of Labor Statistics publishes pay and outlook data for related occupations. Its 2024 figures:

• Securities, commodities and financial services sales agents: median annual pay of $78,140, with projected job growth of 3% from 2024 to 2034, about as fast as average. The category includes brokers, investment sales agents, traders and financial services sales agents.
• Personal financial advisors: median annual pay of $102,140, with projected growth of 10% over the same period, much faster than average.
• Insurance sales agents: annual pay of $60,370, with projected growth of 4%, about as fast as average.

The Bottom Line

These exams matter to anyone planning to sell securities, give fee-based advice, or do both under state law. Sellers usually pair the Series 7 with the 63, and fee-only advisers without a Series 7 should take the 65. Candidates who will both sell and advise and hold the Series 7 can replace two exams with the Series 66, after confirming requirements with their sponsoring firm and state administrator.