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Series 66: Uniform Combined State Law Exam

Module 1 — The Combined Exam · Lesson 1.1

What the Series 66 Qualifies You For

The combined state law exam, and when it is the right one to sit

~11 min
Listen
0:00 / ~12:13

What you'll learn

  • State the condition on which the Series 66 takes the place of the Series 63 and Series 65
  • Choose between the Series 66, the Series 65 and the 63 plus 65 for a given career plan
  • Explain why a designation waiver does not apply to the Series 66 and how component credits keep their validity
  • State the exam's question count, time limit, passing score, weights, testing window and retake waits

The Series 66 exists because the industry asked for it. A person who was going to hold both registrations had to sit two NASAA exams, so NASAA built one combined exam that drops what the SIE and Series 7 already cover. That is the whole design, and it explains every rule in this lesson: the Series 66 is short because it leans on the Series 7, and it is worth nothing without it.

What it is, and the condition on it

The Uniform Combined State Law Examination, commonly called the Series 66, was developed by the North American Securities Administrators Association and its member organizations to set competency standards for dually registered broker-dealer agents and investment adviser representatives under state law. NASAA's study guide describes passing it as normally a corequisite with passing FINRA's Series 7 before a state will issue dual licensure.

The phrase to fix in your memory comes from NASAA's FAQ: when combined with a valid SIE and Series 7, the Series 66 qualifies you as if you had passed both the Series 63 and the Series 65. Every word of that sentence does work. On its own, a pass on the Series 66 qualifies you for nothing. The SIE and the Series 7 are co-requisites for registering on the strength of it, and they must be valid at the time you seek state registration.

The order does not matter. NASAA says you can take the tests in any order, and you just need to have passed both when you seek registration. So a candidate can sit the Series 66 first.

Two vocabulary points before going further, because this course will be strict about them. A registered investment adviser, or RIA, is the firm. The individual who works for it and gives advice is an investment adviser representative, an IAR. And an agent is the individual who represents a broker-dealer or an issuer in securities transactions. The Series 66 is the exam for one person holding the last two roles at once.

Passing is not registration. The study guide says that passing does not in and of itself confer the right to transact securities business in any state. The FAQ adds what else a state may impose before granting a licence: an application, usually through Form U4, a background check, bonding and a fee. Acting before those are done is unregistered activity however good your score was.

The 66, the 65, or the 63 plus 65

The decision turns on what you intend to do and how durable you want the qualification to be.

The Series 65 stands alone. It qualifies an IAR with no FINRA exam behind it, the SIE is not required for it, and it is the natural choice for someone who will only give advice for a fee at an adviser firm and will never hold a broker-dealer registration. It is also longer: 130 scored questions against 100, because it has to test the material the Series 66 leaves to the Series 7.

The Series 66 suits someone who will hold both registrations at once and has, or is getting, the SIE and Series 7. It is one sitting instead of two.

The Series 63 plus Series 65 reaches the same end state by two exams. It costs more time, but the Series 65 half survives without the Series 7. If there is a real prospect of leaving the broker-dealer side and working purely as an adviser representative, consider what you would be relying on: a Series 66 that needs a valid Series 7 behind it, or a Series 65 that does not.

A candidate who already holds the Series 63, SIE and Series 7 and now wants to advise faces a narrower question, and NASAA's FAQ answers it with a step many people skip. First contact the state regulator, to find out whether yours is a state that permits registered brokerage representatives to act as investment adviser representatives without further qualification. If it is not, passing either the 65 or the 66 satisfies the exam prerequisite. Do not assume the answer in either direction. It is a state question and the state's rule controls.

An employer can also set the bar higher than the state does. NASAA notes that a firm wanting a qualification beyond state law generally may require it, so a firm can insist on the Series 65 where the state would accept something less.

One caution that follows from failing. Waiting periods are specific to each exam, so a candidate who fails the Series 66 may sit the Series 63 or Series 65 sooner than they could retake the 66.

Waivers, component credits and how long a pass lasts

Most states allow certain professional designations to substitute for the Series 65. NASAA's current model rule lists five: the Certified Financial Planner, the Chartered Financial Consultant, the Chartered Financial Analyst, the Personal Financial Specialist and the Certified Investment Management Analyst. Its May 2024 amendments replaced the Chartered Investment Counselor with the CIMA and deleted the Master of Science in Financial Services degree, which NASAA's February 2025 FAQ still names. The FAQ tells candidates to confirm whether their state accepts the updated list, so older lists are not a safe guide, and the state's own rule controls. The waiver is claimed by checking a box in Section 8 of Form U4.

The model rule writes the pairing into the requirement: an applicant for IAR registration has passed the Series 65 within two years of applying, or the Series 66 and Series 7 within two years and the SIE within four, unless waived. The older Model Rule 204(b)(6)-1, which the study guide names, has the same Series 65 or Series 66 and Series 7 structure, with a designation list dating from 2008.

Now the point for this course: none of that helps with the Series 66. NASAA's answer is flat. A qualifying designation waives only the Series 65 requirement, because passing the Series 66 is equivalent to having passed both the 63 and the 65. A CFP professional who wants dual registration can have the Series 65 waived, but that leaves the Series 63 still to be met. It does not excuse the 66.

The Series 66 is also unusual in how its validity works. It does not maintain its validity as a single exam. FINRA's Central Registration Depository grants a Series 63 exam credit to a person who registers as an agent, and a Series 65 exam credit to a person who registers as an IAR, and each component credit keeps its validity separately, on the basis of that person's registration history, just as the underlying exams normally do.

The practical consequence is that the two halves can drift apart. A person who stops being an agent but stays an IAR is running two separate clocks.

The clock itself is state law. NASAA says most states follow a two-year rule: after first passing, you have two years to become registered or the exam expires. Once registered, it stays valid as long as you stay registered. After a termination, usually shown by a Form U5, you have two years to be re-registered, or the exam shows as expired in CRD. A state has discretion in some instances to waive a retake, and NASAA's Exam Validity Extension Program may help someone leaving the industry, but its adoption varies by state.

The exam

The Series 66 has 110 multiple-choice questions. One hundred are scored and ten are unidentified pretest questions, so you cannot know which ones count. You have 150 minutes, which is a little under 82 seconds a question. It is closed book. A proctor will provide scratch paper on request and takes it back at the end.

To pass you must answer at least 73 of the 100 scored questions correctly. Each exam is assembled individually by an algorithm from a pool of eligible questions using difficulty and content parameters, so two people sitting at the same moment get different questions, held to a consistent standard.

The weights are published.

Economic Factors and Business Information: 8 questions, 8 percent.

Investment Vehicle Characteristics: 17 questions, 17 percent.

Client/Customer Investment Recommendations and Strategies: 30 questions, 30 percent.

Laws, Regulations, and Guidelines, Including Prohibition on Unethical Business Practices: 45 questions, 45 percent.

Put the last line beside the Series 65, where the law section is 39 of 130 questions, or 30 percent. On the Series 66 it is the largest section by a wide margin and it is nearly half the paper. The finance sections shrink because the Series 7 is assumed. Nothing in the exam assumes you know the state law, and the study guide warns that a question may test a concept without naming it: one that opens with the words under the Uniform Securities Act might be testing the Act itself or a NASAA model rule made under it.

FINRA administers the exam for NASAA. A firm schedules a candidate through Form U4. No sponsor is required, so an individual can open an enrollment window through FINRA's Test Enrollment Services System. The fee was $177 as of NASAA's February 2025 FAQ, and it buys one attempt. FINRA then opens a 120-day window. NASAA grants extensions only where illness or injury kept you from the exam, not for more study time, and fees are generally not refunded.

After the exam you learn at once whether you passed. A candidate who fails also sees a score for each of the four sections, but no question-level detail. Do not try to average those section scores into an overall result: the parts are weighted differently, and NASAA says the passing score is based on the overall exam.

The retake rule is a minimum of 30 days after a first failure, 30 days after a second, and 180 days after a third and every later failure. The waits are counted on failed attempts in a two-year period, and an attempt more than two years old does not factor in. There is no limit on the number of attempts.

How this course is built

This course assumes you have passed the Series 7 or are taking it. It does not reteach what a bond is. It spends its words where the Series 66 outline puts its weight: portfolio theory, taxation and estate planning at the client level, performance measurement, and above all the state and federal law of investment advisers.

The statute tested is the Uniform Securities Act of 1956 as amended by NASAA, not the Uniform Securities Act of 2002. NASAA's guide says so expressly, and NASAA says it will give advance notice if that ever changes. Some NASAA model rule names carry USA 2002 labels because NASAA wrote them for the later Act. They are still on the list. If you have sat the Series 63, you have seen much of this, and the Series 63 course here is a useful companion, but this exam goes deep on advisers where that one stays shallow.

The module weights follow the published ones, so five of this course's twelve lessons are on the law. And one change is close. NASAA amended its adviser advertising model rules in May 2026 and says affected exam questions will update in early 2027. Lesson 4.4 teaches both positions and tells you what to check.

This course is not affiliated with, endorsed by or produced in cooperation with NASAA, FINRA or the SEC, and it contains no exam questions. All NASAA examination questions are copyright material, and NASAA expressly prohibits their unauthorized use and reserves the right to refer anyone who compromises an exam to state regulators and law enforcement. It teaches general principles of law and finance and is not legal or tax advice.

Key takeaways

  • ·The Series 66 qualifies you as if you had passed the 63 and 65 only when combined with a valid SIE and Series 7, which can be taken in either order.
  • ·A professional designation waives the Series 65 only, never the Series 66.
  • ·The Series 66 does not stay valid as one exam: its Series 63 and Series 65 credits run separately on your registration history.
  • ·If you already hold the 63, SIE and 7, first ask your state whether you may act as an IAR without more.
  • ·110 questions, 100 scored, 150 minutes, 73 to pass; weights of 8, 17, 30 and 45 percent; a 120-day window; retake waits of 30, 30 and 180 days.
  • ·Passing is one requirement for registration, not registration.

The next module covers the 25 questions of finance. There is less of it than on the Series 65, and what remains is mostly arithmetic and definitions, so it rewards being done accurately rather than at length.

Sources

  1. 1.
    NASAA Model Rule: Examination Requirements for Investment Adviser Representatives

    North American Securities Administrators Association (NASAA) · Adopted September 18, 2022; amended May 6, 2024 and December 18, 2024 · 2024

    The model requirement of the Series 65, or the Series 66 and Series 7 within two years plus the SIE within four, and the five waiver designations: CFP, ChFC, CFA, PFS and CIMA.

  2. 2.
    NASAA Members Approve Amendments For Two Model Rules

    North American Securities Administrators Association (NASAA) · 2024

    That the May 2024 amendments replaced the CIC with the CIMA and deleted the MSFS degree as an eligible designation.

  3. 3.
    Uniform Combined State Law Examination (Series 66) Overview

    North American Securities Administrators Association (NASAA) · 2023

    The exam's purpose; 110 questions with 100 scored; 150 minutes; 73 of 100 to pass; closed book with scratch paper on request; algorithmic assembly; the 120-day window; the 30/30/180-day waits; section scores for failing candidates; the four weights; the testing of the 1956 Act rather than the 2002 Act; and the warning that a question may not name the rule it tests.

  4. 4.
    Series 66 Test Specifications, effective June 12, 2023

    North American Securities Administrators Association (NASAA) · 2023

    The four topics, their weights and question counts, and the subtopics this course is organized around.

  5. 5.
    Exams FAQ

    North American Securities Administrators Association (NASAA) · Updated February 14, 2025 · 2025

    The Series 66 as equivalent to the 63 plus 65 only with a valid SIE and Series 7; taking them in either order; the rule that designations waive only the Series 65; the May 2024 designation list and Form U4 Section 8; component credits; the two-year rule; the $177 fee; no sponsor requirement; no extensions for study time; waits counted over two years and specific to each exam; no averaging of section scores; and checking whether a state lets brokerage representatives advise without further qualification.

  6. 6.
    NASAA Examination Requirements for Investment Advisers and Investment Adviser Representatives, Model Rule 204(b)(6)-1

    North American Securities Administrators Association (NASAA)

    The older model rule the study guide names: the Series 65, or the Series 66 and Series 7, within two years before the application, with a designation list dating from 2008.

  7. 7.
    Series 65 Test Specifications, effective June 12, 2023

    North American Securities Administrators Association (NASAA) · 2023

    The Series 65's law topic at 39 scored questions and 30 percent, used here for the comparison with the Series 66.

  8. 8.
    Exam Study Guides: Exam Updates announcement

    North American Securities Administrators Association (NASAA)

    NASAA's notice that exam questions affected by the May 2026 adviser advertising model rule amendments will update in early 2027, on a date still to be given.

Contents
2.1 — Economic Factors: The Analytical Methods

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