NASAA’s model rule lists five designations that waive the Series 65 exam: CFP, CFA, ChFC, PFS, and CIMA. In May 2024 CIMA replaced CIC (Chartered Investment Counselor) rather than joining it, so the list is five, not six. If you hold one of these in good standing, you can skip the exam and proceed directly to IAR registration. You’ll still need to complete Form U4, pass a background check, and pay state fees. States adopt the model rule on their own timetable, so check yours: many still name CIC and have not yet added CIMA.
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 York’s for federally registered advisers) may bypass state registration entirely. These are different processes with different requirements.
Which professional designations qualify for a Series 65 waiver?
NASAA’s model rule recognizes five credentials for Series 65 waivers. Each has specific requirements and is issued by a recognized certifying body. CIC appears in the table below because it is still named in many state rules that have not yet adopted the 2024 amendment, but it is no longer part of the model rule and can no longer be earned.
| 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) |
| CIMA | Certified Investment Management Analyst | Investments & Wealth Institute | 6-12 months + 3 years experience |
CIC (removed 2024) | Chartered Investment Counselor | Investment Adviser Association | No longer offered; program discontinued 2025 |
On May 6, 2024 NASAA amended its model rule to replace CIC with CIMA. CIMA was not added to a six-item list, and the list has never had six entries. NASAA made the swap because the CIC program had stopped accepting new applications and was slated for discontinuation in 2025. Each state adopts the amendment individually, so there is a gap: your state’s rule may still name CIC and may not yet recognize CIMA. Verify with your state regulator before relying on either.
What are the credential requirements at a glance?
CFP (Certified Financial Planner)
The gold standard for financial planners. Requires a bachelor’s 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 bachelor’s 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 capstone exam. Requires eight college-level courses, three years of business experience, and adherence to The American College’s 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 building on their existing credential.
CIC (Chartered Investment Counselor) — no longer available
Formerly an elite credential for investment counselors, requiring a CFA charter, employment at an IAA member firm, five years of eligible work experience, and character references. NASAA removed CIC from the model rule in May 2024 and the program was discontinued in 2025, so it can no longer be earned. It is listed here only because some state rules still name it.
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.
Choose Your PathHow do you apply for a Series 65 waiver?
The waiver process is built into standard IAR registration. You don’t 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 there’s a data lag, the CRD verification might fail, causing delays.
How do waiver rules vary by state?
While most states follow NASAA’s model rule, there are important variations. For the credential-waiver list, fees, and CE rules in each U.S. jurisdiction, see our Series 65 state requirements hub.
| 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 NASAA’s 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) | Replaced CIC in NASAA’s model rule May 2024. States must adopt individually. Verify acceptance before relying on CIMA for a waiver. |
| Most Other States | Accept CFP, CFA, ChFC, and PFS. Whether CIC or CIMA works depends on whether the state has adopted the 2024 amendment. Contact your state regulator to confirm. |
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 does a Series 65 waiver 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 you’ll 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 doesn’t exempt you from ongoing CE requirements.
Can you get a Series 65 waiver based on experience?
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.
Does the Series 66 have similar 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 Series 65 waiver?
Consider the Waiver If...
You already hold or are pursuing CFP, CFA, ChFC, PFS, 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 don’t hold a qualifying credential. The Series 65 requires 4-8 weeks of focused study. It’s 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 you’re pursuing the credential anyway, the exam is more efficient.
Qualifying Designations (NASAA model rule): CFP, CFA, ChFC, PFS, CIMA — five, not six. CIMA replaced CIC in May 2024; CIC can no longer be earned but is still named in some unconformed state rules.
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: CFP/CFA/ChFC/PFS are accepted almost everywhere; whether CIC or CIMA works depends on whether your state adopted the 2024 amendment. Verify with your regulator.
Bottom Line: If you already hold a qualifying credential, the waiver saves $187 and exam prep time. If you don’t, 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.