Six professional designations can waive the Series 65 exam: CFP, CFA, ChFC, PFS, CIC, and CIMA (new in 2024). If you hold one of these credentials in good standing, you can skip the exam and proceed directly to IAR registration. Youâll still need to complete Form U4, pass a background check, and pay state fees.
What Is a Series 65 Exam Waiver?
A Series 65 waiver allows you to register as an Investment Adviser Representative (IAR) without taking the exam. NASAA (the North American Securities Administrators Association) recognizes certain professional designations as demonstrating equivalent competence to the Series 65.
This is unique among securities exams. The Series 7, Series 6, and most other FINRA exams have no waiver options. The Series 65 stands alone in offering this alternative path.
A waiver skips the exam but still requires state registration. An exemption (like New Yorkâs for federally registered advisers) may bypass state registration entirely. These are different processes with different requirements.
Qualifying Professional Designations
NASAAâs model rule recognizes six credentials for Series 65 waivers. Each has specific requirements and is issued by a recognized certifying body.
| Designation | Full Name | Issuing Organization | Typical Timeline |
|---|---|---|---|
| CFP | Certified Financial Planner | CFP Board of Standards | 2-3 years |
| CFA | Chartered Financial Analyst | CFA Institute | 2-5 years |
| ChFC | Chartered Financial Consultant | The American College | 1-2 years |
| PFS | Personal Financial Specialist | AICPA (for CPAs only) | Varies (CPA required) |
| CIC | Chartered Investment Counselor | Investment Adviser Association | CFA + 5 years experience |
| CIMA | Certified Investment Management Analyst | Investments & Wealth Institute | 6-12 months + 3 years experience |
CIMA was added to NASAAâs model rule in May 2024, the first new designation in 24 years. Each state must adopt this change individually. Verify CIMA acceptance with your state regulator before relying on it for a waiver.
Credential Requirements at a Glance
CFP (Certified Financial Planner)
The gold standard for financial planners. Requires a bachelorâs degree, completion of CFP Board-registered education, 6,000 hours of professional experience (or 4,000 in an apprenticeship), and passing the CFP exam. Annual ethics requirements and 30 hours of CE every two years.
CFA (Chartered Financial Analyst)
Globally recognized investment credential. Requires a bachelorâs degree (or final year of study), passing three progressive exams (4+ hours each), and 4,000 hours of relevant work experience. Known for rigorous self-study and low pass rates (historically 40-50% per level).
ChFC (Chartered Financial Consultant)
Similar to CFP but with more courses and no comprehensive exam. Requires eight college-level courses, three years of business experience, and adherence to The American Collegeâs Code of Ethics. Popular with insurance professionals expanding into planning.
PFS (Personal Financial Specialist)
CPA-exclusive designation. Requires active CPA license, 3,000 hours of personal financial planning experience within the past five years, and passing the PFS exam. Allows CPAs to expand into wealth management while leveraging their existing credential.
CIC (Chartered Investment Counselor)
Elite credential for investment counselors. Requires CFA charter, employment at an IAA member firm, five years of eligible work experience, and character references. Note: This program is being discontinued; CIMA is the designated replacement.
CIMA (Certified Investment Management Analyst)
Focus on investment consulting and portfolio construction. Requires three years of financial services experience, two background checks, completion of education program, and passing the CIMA exam. ANSI-accredited credential.
Don't Have These Credentials?
For most candidates, taking the Series 65 exam (4-8 weeks of study) is faster than earning a qualifying designation. CertFuel's adaptive learning system helps you prepare efficiently.
Access Free BetaHow to Apply for a Waiver
The waiver process is built into standard IAR registration. You donât file a separate waiver request.
Step 1: Verify Your Credential
Confirm your designation is current and in good standing with the issuing organization. The CRD system will verify your status automatically, and discrepancies can delay registration.
Step 2: Complete Form U4
File Form U4 through your sponsoring firm (or as an independent if starting your own RIA). In Section 8, indicate the professional designation you hold that qualifies for the waiver.
Step 3: CRD Verification
The Central Registration Depository (CRD) system checks databases maintained by certifying organizations. This verification happens automatically; no manual documentation is typically required.
Step 4: State Approval
Your state securities regulator reviews the application. If your credential is valid and your background check clears, registration is approved without the Series 65 exam requirement.
Contact your certifying organization to confirm your credential appears in their active database. If you recently renewed or thereâs a data lag, the CRD verification might fail, causing delays.
State-by-State Variations
While most states follow NASAAâs model rule, there are important variations:
| State/Situation | Key Differences |
|---|---|
| New York | No exam required for IARs associated with federally registered investment advisers. This is an exemption, not a waiver, with different procedures. |
| Texas | Offers NASAAâs Exam Validity Extension Program (EVEP) for maintaining Series 65 validity through CE. Also handles experience-based waivers case-by-case via registration@ssb.texas.gov. |
| CIMA (All States) | Added to NASAA model rule May 2024. States must adopt individually. Verify acceptance before relying on CIMA for a waiver. |
| Most Other States | Follow NASAA model rule. Accept CFP, CFA, ChFC, PFS, CIC. Contact your state regulator to confirm specific policies. |
State policies can change. Before relying on a waiver, contact your state securities regulator directly. A few minutes of verification can prevent registration delays.
What the Waiver Does NOT Do
A Series 65 waiver only exempts you from the exam. Several requirements still apply:
Still Required: State Registration
You must register as an IAR in each state where youâll conduct business. This includes Form U4, background check, and state fees.
Still Required: Background Check
Criminal history, regulatory actions, and financial disclosures are still reviewed as part of IAR registration.
Still Required: Fees
State registration fees (typically $25-$200 per state) still apply. The waiver only saves the $187 exam fee.
Still Required: Continuing Education
Many states require IAR continuing education. The waiver doesnât exempt you from ongoing CE requirements.
Experience-Based Waivers (Rare)
In limited circumstances, some states grant waivers based on extensive industry experience rather than professional designations:
Eligibility
Typically requires 15-20+ years of continuous securities industry experience. Candidates may have previously passed the Series 65 (now expired) or never taken it.
Application
Submit a written waiver request with your registration application. Include detailed employment history, job duties, gaps in employment, and Form U4 disclosures.
Review
The state securities regulator reviews on a case-by-case basis. Texas, for example, typically responds within two weeks. Approval is not guaranteed.
These waivers are exceptions, not standard practice. If you have fewer than 15 years of industry experience and no qualifying designation, plan to take the exam.
The good news? Most candidates need just 4-8 weeks of focused study compared to the 1-5 years required for qualifying credentials. Taking the Series 65 directly is typically the fastest path to IAR registration.
Series 66 and Waivers
The Series 66 combines Series 63 and Series 65 content. Professional designation waivers work differently:
- Series 65 portion: Can be waived with qualifying credentials
- Series 63 portion: No professional designation waiver exists
Because the Series 66 is a single combined exam, you cannot waive just part of it. If you hold a qualifying designation and need Series 66 registration:
- Take the full Series 66 exam, OR
- Take Series 63 separately and use your designation to waive Series 65
For most candidates with qualifying credentials who also hold the Series 7, the second option is simpler. The Series 63 is shorter (60 scored questions, 75 minutes) and focused purely on state law.
Should You Pursue a Waiver?
Consider the Waiver If...
You already hold or are pursuing CFP, CFA, ChFC, PFS, CIC, or CIMA for career reasons. The waiver is a bonus, not the primary goal. These credentials take 1-5 years to earn.
Take the Exam If...
You need IAR registration soon and donât hold a qualifying credential. The Series 65 requires 4-8 weeks of focused study. Itâs the faster path for most candidates. Start with a structured study schedule to plan your timeline and maximize your first-attempt pass rate.
The Series 65 costs $187 and takes 50-100 hours of study. Even the fastest qualifying credential (ChFC) takes 12+ months. Unless youâre pursuing the credential anyway, the exam is more efficient.
Qualifying Designations: CFP, CFA, ChFC, PFS, CIC, CIMA
How to Apply: Indicate credential in Form U4 Section 8; CRD verifies automatically
Still Required: State registration, background check, fees, continuing education
Series 66: Waiver applies to Series 65 portion only; no Series 63 waiver exists
State Variations: Most follow NASAA model rule; verify CIMA acceptance and any state-specific policies
Bottom Line: If you already hold a qualifying credential, the waiver saves $187 and exam prep time. If you donât, earning a credential just to avoid the Series 65 rarely makes sense. For most readers, taking the exam is the direct path. Start with a proven study schedule to prepare efficiently.