Series 66: Uniform Combined State Law Exam Guide
Nov 24, 2025
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14 min read
Contents
The Series 66 exam is a state-level qualification that combines elements of securities sales and investment advisory regulation. It’s required for professionals who want to act in both capacities, typically as registered representatives and investment advisor representatives.
In a fintech or multi-state financial services context, understanding how this exam fits within broader licensing requirements is a practical compliance necessity. This guide outlines what the Series 66 covers, who it applies to, and how it differs from other NASAA exams, such as Series 63 and Series 65.
It also reviews exam structure, regulatory oversight, and key compliance considerations relevant to broker-dealers, investment advisors, and fintech firms that blend advisory and transactional services.
InnReg is a global regulatory compliance and operations consulting team serving financial services companies since 2013. If you need assistance with compliance or fintech regulations, click here.
What Is the Series 66 Exam?
Officially called the Uniform Combined State Law Examination, the Series 66 exam is developed by the North American Securities Administrators Association (NASAA) and administered by FINRA.
It qualifies individuals to act as both securities agents and investment advisor representatives under state law. This dual coverage makes it a central requirement for professionals who handle both client investment advice and securities transactions.
The Series 66 is not a standalone license. It works in combination with the FINRA Series 7 exam. Together, they cover both product knowledge and state regulatory principles, giving candidates the authority to operate in most advisory and broker-dealer roles that require state-level registration.
Who Needs the Series 66 License?
The Series 66 license is required for professionals who handle both investment advisory and securities transaction activities under state law. It’s most relevant to individuals or teams working in dual-capacity roles.
Common roles that require the Series 66 license include:
Financial advisors employed by firms registered as both broker-dealers and investment advisors.
Client-facing representatives who provide investment guidance and also execute trades.
Supervisory or operations managers overseeing staff engaged in advisory or brokerage functions.
Founders or executives at fintech startups that directly design or manage regulated investment services.
For fintech businesses, the need for the Series 66 typically depends on how the platform operates:
If the firm provides personalized investment advice, representatives need the Series 65 or Series 66.
If the firm also executes securities transactions, staff must hold both the Series 7 and the Series 66 licenses.
If the company operates across multiple states, the Series 66 often satisfies state registration requirements more efficiently than separate Series 63 and 65 exams.
In short, the Series 66 license supports hybrid financial models where advice and execution overlap. For fintech firms, it’s a practical way to qualify personnel who manage regulated client interactions or oversee both advisory and brokerage operations.
Series 66 vs. Series 63 and Series 65
The Series 66 exam combines material from both the Series 63 and Series 65 exams, making it one of the most efficient paths for professionals who already hold a Series 7 license.
NASAA developed all three exams to test state-level securities knowledge, but they serve different purposes depending on a person’s role and business model.
Key Differences in Scope and Use
Exam | Purpose | Common Use | Co-requisite |
|---|---|---|---|
Series 63 | Focuses on state securities laws under the Uniform Securities Act. | Required for broker-dealer representatives who sell securities in most states. | Often paired with Series 7. |
Series 65 | Focuses on investment advisory laws and client portfolio management. | Required for investment advisor representatives who provide fee-based advice. | None. Can stand alone. |
Series 66 | Combines the content of Series 63 and Series 65 for those who already hold Series 7. | Used by professionals who act as both securities agents and investment advisors. | Requires Series 7. |
When to Choose Series 65 Instead of Series 66
The right exam depends on a firm’s structure and business activities:
Choose Series 65 if your firm operates only as an investment advisor and does not sell securities.
Choose Series 66 if your firm or staff will hold a Series 7 license and perform both advisory and brokerage functions.
Keep in mind: Series 66 cannot be used alone. Without Series 7, it does not qualify an individual for registration.
For fintech startups, the distinction matters. A startup running a digital advisory platform without a broker-dealer component may only need Series 65-qualified personnel. But if the company also facilitates securities transactions or provides access to brokerage accounts, the Series 7 and 66 combination becomes the standard.
This decision often shapes compliance planning early in a firm’s lifecycle. Partnering with a compliance consultant like InnReg can help determine which path aligns with your business model, especially if your platform blurs the line between investment advice and securities execution.
Series 66 Exam Structure and Content
The Series 66 exam is designed to test a candidate’s understanding of both investment advisory concepts and state securities laws. It reflects the knowledge required to operate under the Uniform Securities Act and is administered by FINRA on behalf of NASAA.
Exam Format, Timing, and Passing Score
The exam consists of 110 multiple-choice questions, of which 100 are scored and 5 are unscored pretest questions. Candidates have 150 minutes (2.5 hours) to complete it. A score of 73% or higher is required to pass.
There are no prerequisites to sit for the Series 66 exam. However, the license becomes valid only when paired with an active Series 7 registration. Candidates may apply for the exam through their firm (via Form U4) or individually (via Form U10).
Content Areas and Weightings
NASAA updates the exam outline periodically. As of the latest version, the topics are divided into four major areas:
Approx. Weight | Content Area | Focus |
|---|---|---|
8% | Economic Factors and Business Information | Basic economic concepts, financial reporting, and investment risks. |
17% | Investment Vehicle Characteristics | Features, benefits, and risks of securities and other investment products. |
30% | Client Investment Recommendations and Strategies | Portfolio management, asset allocation, taxation, and client suitability. |
45% | Laws, Regulations, and Guidelines | State and federal securities laws, ethical practices, and fiduciary duties. |
The final section of laws, regulations, and guidelines is the most heavily weighted and central to compliance. It includes questions on registration, disclosure, conflicts of interest, and prohibited practices.
Commonly Tested Laws and Ethics Topics
The Series 66 exam comes with its own set of commonly tested topics and laws.
Candidates should be familiar with the following topics:
Uniform Securities Act
Investment Advisers Act of 1940
Securities Act of 1933
Securities Exchange Act of 1934
While product-specific details are covered more deeply in the Series 7 exam, Series 66 focuses on regulatory interpretation and ethical application, highlighting the practical decision-making expected of a licensed representative.
For fintech firms, this focus on ethics and fiduciary duty has operational implications. It affects how client advice is delivered, how conflicts are disclosed, and how compliance officers supervise registered personnel across both digital and traditional advisory channels.
Tip: Ethical conduct, fiduciary responsibility, and recordkeeping rules frequently appear.
See also:
Regulatory Bodies and Oversight
The Series 66 license operates within a coordinated framework involving NASAA, FINRA, and state securities regulators. Each plays a distinct role in the development, administration, and recognition of the exam for licensing purposes.
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Role of NASAA
NASAA develops and maintains the Series 66 exam. It sets the content outline, determines passing standards, and periodically updates topics to reflect new regulatory trends.
Its focus is on state-level investor protection. Its exam framework is designed to test how well candidates understand and apply the Uniform Securities Act and related state laws.
NASAA also coordinates with state regulators to keep the Series 66 consistent across jurisdictions. This standardization allows professionals to qualify for registration in multiple states without needing to take separate exams.
Role of FINRA
The Financial Industry Regulatory Authority (FINRA) administers the Series 66 exam on NASAA’s behalf. FINRA manages test scheduling, exam delivery, and recordkeeping through its Central Registration Depository (CRD) system.
While FINRA facilitates the exam, it does not regulate investment advisors at the state level. Instead, its role is primarily administrative:
Maintaining accurate exam histories;
Processing applications through Forms U4 and U10; and
Linking passing results to Series 7 registration records.
State Registration Requirements
Passing the Series 66 does not automatically grant a license. Each state requires candidates to register as either an investment advisor representative (IAR) or a broker-dealer agent before they can legally interact with clients. This involves submitting documentation, paying fees, and maintaining continuing education obligations.
State regulators review each registration to confirm that:
The candidate holds the required Series 7 and Series 66 combination.
The sponsoring firm is properly registered in that state.
The applicant meets all disclosure and qualification standards.
Fintech firms face a unique challenge: they need to navigate registration requirements in multiple states while also meeting federal standards.
This gets particularly tricky when you're running a hybrid model where you offer investment advice (which states regulate) alongside brokerage services (which fall under federal oversight).
Working with compliance consultants who know the landscape can make a real difference. They help you file in the right places at the right times and spot potential registration issues before they become problems. It's about having someone who understands both the state-by-state requirements and how they interact with federal rules.
Compliance Considerations for Firms Using Series 66
Holding a Series 66 license is only part of maintaining compliance. Firms must integrate it into a broader regulatory framework that governs registration timing, supervision, and ongoing oversight. Here are some considerations to keep in mind:
Registration and Licensing Timing
Timing is critical. Representatives cannot engage in client-facing activities until their registrations are approved. This includes both state-level registration for investment advisory activities and FINRA registration for brokerage functions.
The sequencing of these registrations matters for fintechs. A common approach is:
Secure firm registration as a broker-dealer or investment advisor.
File Form U4 for key personnel.
Schedule Series 7 and Series 66 exams in parallel.
Activate state registrations once exams are passed.
Coordinating these steps early helps avoid delays when onboarding new representatives or launching advisory products.
Dual Roles: Broker vs. Advisor Responsibilities
Professionals who hold both Series 7 and Series 66 operate under two sets of standards.
As brokers, they must comply with FINRA’s Regulation Best Interest (Reg BI) when recommending securities transactions.
As investment advisors, they are bound by a fiduciary duty under the Investment Advisers Act and state regulations.
For firms, this dual capacity means developing written supervisory procedures (WSPs) that clarify when a representative acts as a broker and when they act as an advisor. This distinction affects compensation models, disclosure language, and client documentation.
See also:
Supervisory and Compliance Program Needs
Supervision should extend beyond testing and registration. A firm’s compliance program must cover how licensed staff handle client advice, manage conflicts of interest, and document recommendations.
Common oversight measures include:
Transaction reviews to detect securities recommendations that don’t align with a client’s goals or best interests.
Regular audits of advisory disclosures and fee structures.
Training on the differences between fiduciary and brokerage obligations.
These controls often need to be adapted to automated systems within every fintech firm. A compliance team, whether in-house or outsourced, must monitor both human and algorithmic decision-making for regulatory consistency.
Maintaining Active Registration and Renewals
Once approved, Series 66 registrations must be actively maintained. Representatives who leave a firm or lapse in registration for more than two years may need to retake the exam.
Many states have adopted NASAA’s Investment Advisor Representative Continuing Education (IAR CE) rule, requiring 12 hours of annual training. In parallel, NASAA’s Exam Validity Extension Program (EVEP) allows professionals to extend exam validity for up to five years by completing continuing education while not registered.
Compliance teams should track these obligations as part of their annual compliance calendar. For smaller or fast-growing fintechs, outsourcing to a specialized compliance partner like InnReg can help teams build compliance workflows to easily manage renewals, filings, continuing education, and supervisory documentation efficiently across jurisdictions.
Common Challenges and Misconceptions
Even experienced professionals can misunderstand how the Series 66 license works in practice. These gaps often lead to registration delays or compliance oversights, especially if your fintech operates across multiple jurisdictions.
Series 66 Is Not a Standalone License
One of the most common misconceptions is that the Series 66 can be used on its own. In reality, the Series 66 only becomes valid when combined with an active Series 7 registration. The two together allow representatives to operate as both securities agents and investment advisors.
Without the Series 7, the Series 66 has no regulatory effect. Candidates who do not plan to sell securities may instead take the Series 65, which qualifies them solely for advisory work. For compliance teams, mapping which staff roles require both licenses versus one is a key part of avoiding regulatory gaps.
State-By-State Differences and Pitfalls
While NASAA creates the exam, each state enforces its own licensing and registration requirements. Some states require additional filings or interpret exemption criteria differently. Firms expanding across multiple states should verify registration details for every jurisdiction where their representatives will be operating.
Common pitfalls include:
Failing to register before soliciting clients in a new state.
Overlooking notice-filing requirements for investment advisors.
Assuming an existing federal RIA registration automatically satisfies state obligations.
Fintech firms with digital or app-based platforms should pay particular attention to this area. Even online interactions can trigger state-level registration if clients reside there.
Misunderstanding SIE and Series 7 Co-Requisites
Another recurring source of confusion involves exam prerequisites. The Series 66 has no standalone prerequisites, but individual states require an active Series 7 for full use. Since 2018, candidates pursuing the Series 7 must also complete the Securities Industry Essentials (SIE) exam first.
That sequence means most professionals will hold three credentials before operating under Series 66: SIE, Series 7, and Series 66.
Skipping or misordering them can cause delays in licensing. For fintech startups building internal compliance infrastructure, documenting these sequences in onboarding procedures helps keep registration timelines predictable and consistent.
Evolving Rules and Trends Affecting Series 66
The Series 66 license continues to evolve as regulators adjust requirements to reflect new technologies, advisory practices, and industry risks.
These developments affect how firms train, register, and supervise licensed personnel, particularly in fintech environments where products often blur the line between traditional brokerage and digital advisory services.
Shifts in Exam Content and Focus Areas
NASAA periodically updates the Series 66 content outline to reflect emerging regulatory and market trends. Recent adjustments have expanded coverage of:
Cybersecurity risks and data protection obligations.
Senior investor protections and suitability reviews.
Advisory fee disclosures and conflict management.
These updates signal that regulators want representatives to understand not just laws but how to apply them in complex, tech-driven business models. Staying current with NASAA’s published exam outlines helps firms anticipate what regulators emphasize during audits or exams.
Continuing Education and Retention Programs
Many states now require investment advisor representatives to complete annual continuing education (CE). NASAA’s IAR CE model rule sets a baseline of 12 hours of training each year:
Six hours on products and practices
Six on ethics and professional responsibility
In addition, NASAA’s EVEP allows registered individuals to keep their Series 63, 65, or 66 credentials valid for up to five years while not affiliated with a firm, provided they complete annual CE requirements.
Tracking CE deadlines across multiple states and roles is now part of standard regulatory compliance, similar to maintaining cybersecurity or AML program records.
State Enforcement Priorities Around Licensing
State regulators have increased scrutiny on unlicensed advisory activity, especially in digital investment models. NASAA’s recent enforcement reports show steady action against firms offering advisory services or recommendations before obtaining proper registrations.
This trend reflects a broader expectation that fintechs build compliance infrastructure early, before client onboarding or product launch. Firms that overlook licensing details risk enforcement actions, reputational damage, or delayed approvals during expansion.
See also:
Emerging Fintech Models Regulators are Watching
Regulators are closely monitoring fintech platforms that combine brokerage, advisory, and automated services. Common focus areas include:
Hybrid robo-advisors that manage portfolios and also execute trades.
Reward-based investing models, such as stock-back or micro-investing programs.
Crypto or tokenized securities offerings that mimic investment products.
For these models, holding the correct Series 7 and 66 combination among key personnel helps demonstrate regulatory awareness and readiness for supervision. It signals that compliance is integrated into the firm’s business model, rather than being treated as an afterthought.
Preparing for the Series 66 Exam
Preparation for the Series 66 exam requires more than memorizing regulations. Candidates must understand how to apply concepts in real advisory and broker-dealer contexts.
For fintech professionals, this often means translating state-level compliance principles into digital operations, automated systems, and hybrid client models.
Study Timelines and Strategies
NASAA recommends that candidates dedicate four to six weeks of focused study before sitting for the exam. The exact timeline depends on prior experience with securities laws and investment products.
Practical study steps include:
Reviewing NASAA’s official content outline for current topics and weightings.
Studying state and federal securities laws, particularly the Uniform Securities Act and Investment Advisers Act of 1940.
Taking multiple practice exams to identify weak areas.
Using reputable prep providers that offer question banks modeled after NASAA’s testing format.
Short, consistent study sessions often lead to better retention than last-minute cramming. Many candidates find that alternating between compliance-heavy and investment-focused topics helps maintain balance and focus.
Typical Pass Rates and Candidate Challenges
NASAA does not publish official pass rates, but industry data suggests an average range of 65% to 70%. The most common challenge is mastering the regulatory application and ethics section, which makes up nearly half of the test.
Candidates often underestimate how scenario-based questions test real-world reasoning, not just definitions. Understanding how state and federal laws intersect and recognizing when one takes precedence is essential for scoring well.
Resources and Official Outlines
Reliable preparation materials include:
NASAA’s Series 66 Content Outline, available on its website.
FINRA’s testing and enrollment portal for scheduling.
Study programs from Kaplan, STC, and other recognized training providers.
Candidates can also reference state securities regulator websites for current laws and updates. Reviewing official guidance alongside exam prep materials helps align study time with practical compliance expectations.
Key Takeaways
The Series 66 license plays a central role in linking advisory and brokerage compliance. For fintech firms, it reflects an understanding of how state and federal regulatory obligations align when offering investment products or advice across multiple jurisdictions.
Integrating licensing and supervision into business planning helps prevent registration gaps and supports consistent compliance oversight as a firm grows. This is particularly relevant for platforms that combine digital advisory, trading, or portfolio management services under a single model.
That’s where experienced compliance support adds value. InnReg can help fintech companies integrate licensing and compliance processes into their operations efficiently, using proven workflows and technology-neutral systems. By embedding a compliance strategy alongside innovation, firms can focus on building products with confidence.
How Can InnReg Help?
InnReg is a global regulatory compliance and operations consulting team serving financial services companies since 2013.
We are especially effective at launching and scaling fintechs with innovative compliance strategies and delivering cost-effective managed services, assisted by proprietary regtech solutions.
If you need help with RIA compliance, reach out to our regulatory experts today:
Published on Nov 24, 2025
Last updated on Nov 24, 2025
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