Investment Adviser Representative (IAR)
Investment Adviser Representative (IAR)
An individual who provides investment advice or manages client accounts on behalf of a registered investment adviser (RIA). IARs must pass the Series 65 exam (or Series 66 with Series 7) and register with state securities regulators, never with the SEC. IARs owe fiduciary duty to clients.
A portfolio manager at an RIA firm who meets with clients to discuss investment strategies and make personalized recommendations is an IAR and must register with the state where they conduct business.
Investment advisers (IAs) can register with the SEC or states depending on assets under management; IARs (the individuals) always register with states only, even if their firm is SEC-registered.
How This Is Tested
- Understanding IARs always register with states, never with SEC
- Recognizing that Series 65 (or Series 66 with Series 7) qualifies IARs for registration
- Identifying who needs IAR registration based on job duties (client-facing roles)
- Understanding IARs owe fiduciary duty to clients under the Investment Advisers Act
- Distinguishing IARs from clerical staff and purely administrative roles that do NOT require registration
Regulatory Limits
| Description | Limit | Notes |
|---|---|---|
| Registration authority for IARs | State securities regulators only | Never SEC, even if the RIA firm is SEC-registered |
| Qualification exam requirement | Series 65 (or Series 66 + Series 7) | Must pass before registration as IAR |
Example Exam Questions
Test your understanding with these practice questions. Select an answer to see the explanation.
Jennifer recently joined an SEC-registered investment adviser firm with $250 million in assets under management. Her role involves meeting with high-net-worth clients to analyze their financial situations and make personalized investment recommendations. She has passed the Series 65 exam. Where must Jennifer register as an Investment Adviser Representative?
B is correct. Investment Adviser Representatives (IARs) ALWAYS register with state securities regulators where they conduct business, never with the SEC. This is true regardless of whether their firm is SEC-registered or state-registered.
A is incorrect because the firm's SEC registration status does not change where IARs register. only the firm (IA) registers with the SEC. C is incorrect because IARs never have dual registration with both SEC and states; only states regulate IARs. D is incorrect because IARs must register even when working for SEC-registered firms; the individual and the firm have separate registration requirements.
The Series 65 exam tests your understanding that investment advisers (firms) and IARs (individuals) have different registration authorities. This is critical for compliance and understanding the regulatory framework governing investment advisory services.
Which examination(s) satisfy the qualification requirement for Investment Adviser Representative (IAR) registration?
C is correct. The Series 65 exam alone qualifies an individual for IAR registration. Alternatively, passing both the Series 7 (General Securities Representative) and Series 66 (Uniform Combined State Law) also qualifies for IAR registration.
A (Series 6 only) qualifies individuals to sell mutual funds and variable products but does NOT qualify for IAR registration. B (Series 7 only) qualifies for broker-dealer representative roles but requires the Series 66 to also serve as an IAR. D (Series 63 + Series 6) provides state law knowledge and mutual fund sales qualification but does not meet IAR requirements.
The Series 65 exam frequently tests knowledge of qualification requirements for different roles in the securities industry. Understanding that Series 65 OR (Series 7 + Series 66) qualifies for IAR registration is essential for career planning and regulatory compliance.
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Access Free BetaAn RIA firm employs four individuals: (1) Mark, who analyzes client portfolios and makes investment recommendations; (2) Susan, who answers phones and schedules appointments; (3) David, who supervises IARs and meets with institutional clients; and (4) Lisa, who processes paperwork and maintains client files. How many of these individuals require IAR registration?
B is correct. Two individuals require IAR registration: Mark (who makes investment recommendations) and David (who supervises IARs and provides advice to clients). IAR registration is required for individuals who provide investment advice, make recommendations, or supervise those who do.
A is incorrect because it excludes David, who supervises IARs and meets with institutional clients. both activities requiring IAR registration. C is incorrect because Susan performs purely clerical duties (answering phones, scheduling), which do not require IAR registration. D is incorrect because Lisa's role is purely administrative (paperwork, file maintenance) and does not involve providing investment advice or supervision.
The Series 65 exam tests your ability to identify which roles require IAR registration based on job duties. Understanding that clerical and administrative staff do NOT need registration, while those providing advice or supervision DO, is critical for firm compliance and staffing decisions.
All of the following statements about Investment Adviser Representatives (IARs) are accurate EXCEPT
B is correct (the EXCEPT answer). IARs do NOT register with the SEC regardless of their firm's assets under management. IARs always register with state securities regulators, even if the investment adviser firm itself is SEC-registered.
A is accurate: IARs owe fiduciary duty to clients, requiring them to act in the client's best interest at all times. C is accurate: IARs are defined as individuals who provide investment advice or manage accounts on behalf of an RIA. D is accurate: as fiduciaries, IARs must fully disclose all material conflicts of interest, including compensation arrangements that could influence their recommendations.
The Series 65 exam tests your ability to distinguish between investment adviser (firm) registration requirements and IAR (individual) registration requirements. Understanding that IARs never register with the SEC is fundamental to grasping the regulatory structure of the investment advisory industry.
Michael works for a state-registered investment adviser firm with $75 million in AUM. He has passed the Series 65 exam and regularly meets with clients to provide personalized portfolio recommendations. Which of the following statements about Michael's regulatory status are accurate?
1. Michael must register as an IAR with his state securities regulator
2. Michael owes fiduciary duty to his clients
3. Michael must also register with the SEC as an IAR
4. Michael is distinguished from broker-dealer representatives by his fiduciary obligation
B is correct. Statements 1, 2, and 4 are accurate.
Statement 1 is TRUE: As an individual providing investment advice on behalf of an investment adviser, Michael must register as an IAR with the state securities regulator where he conducts business.
Statement 2 is TRUE: IARs owe fiduciary duty to clients under the Investment Advisers Act of 1940, requiring them to act in the client's best interest and disclose all material conflicts.
Statement 3 is FALSE: IARs never register with the SEC, regardless of the firm's size or registration status. Only the investment adviser firm (not individual IARs) may register with the SEC.
Statement 4 is TRUE: A key distinction between IARs and broker-dealer representatives is that IARs are held to a fiduciary standard at all times, while broker-dealer representatives traditionally operate under a suitability standard (though Regulation Best Interest has narrowed this gap).
The Series 65 exam tests comprehensive understanding of IAR registration, fiduciary duty, and how IARs differ from broker-dealer representatives. Understanding these distinctions is essential for operating compliantly within the investment advisory industry and explaining your role and obligations to clients.
💡 Memory Aid
IAR = "Individual Always Registers" with STATES. Never SEC! Think of it like a driver's license: the individual (IAR) gets licensed by their STATE, even if they work for a nationwide company (SEC-registered firm). The person always registers locally, the company registers federally.
Related Concepts
This term is part of this cluster:
More in Adviser Registration
Where This Appears on the Exam
This term is tested in the following Series 65 exam topics: