Series 65 Waiver 2026: 5 Designations (CIC Is Off the List)
If you hold a current CFP®, ChFC, CFA®, PFS or CIMA® designation, most states will let you register as an investment adviser representative without passing the Series 65. That is the short answer. The longer answer matters more, because the list of qualifying designations changed in May 2024 and a great deal of what is still published about it describes the old one.
The list most articles still publish is out of date
NASAA's Exams FAQ dated 22 April 2022 named five certifications. NASAA's Exams FAQ updated 14 February 2025 names five as well — but they are not the same five. The 2025 document states plainly that "these professional designations were updated and approved by the NASAA Membership in May of 2024."
| Designation | NASAA Exams FAQ (2022) | NASAA Exams FAQ (2025) & Model Rule |
|---|---|---|
| CFP — Certified Financial Planner | Listed | Listed |
| ChFC — Chartered Financial Consultant | Listed | Listed |
| CFA — Chartered Financial Analyst | Listed | Listed |
| PFS — Personal Financial Specialist | Listed | Listed |
| CIC — Chartered Investment Counselor | Listed | Not listed |
| CIMA — Certified Investment Management Analyst | Not listed | Listed |
The 2022 FAQ's entry read: "CIC – Chartered Investment Counselor (granted by the Investment Adviser Association);". Neither the 2025 FAQ nor the current NASAA Model Rule contains it. In its place both name "Certified Investment Management Analyst ("CIMA") awarded by the Investment & Wealth Institute."
Two practical consequences follow, and they point in opposite directions. If you hold a CIMA and read an article written before mid-2024, you may believe you have to sit a 180-minute exam you do not need. If you hold a CIC and read the same article, you may believe you are covered when the current rule no longer says so. In both cases the resolution is the same: the state administrator decides, and you should ask them rather than us or anyone else.
What the rule actually says
The operative text is section 2 of the NASAA Model Rule on Examination Requirements for Investment Adviser Representatives, adopted 18 September 2022 and amended 6 May 2024 and 18 December 2024:
Two conditions are doing work in that sentence. The designation must be current, and it must be in good standing — both measured at the time you file, not at the time you earned it. A lapsed CFP® does not waive anything.
| Designation | Granting organization, as named in the rule | In the 2025 FAQ |
|---|---|---|
| CFP — Certified Financial Planner | Certified Financial Planner Board of Standards, Inc. | Yes |
| ChFC — Chartered Financial Consultant | The American College of Financial Services | Yes |
| CFA — Chartered Financial Analyst | CFA Institute | Yes |
| PFS — Personal Financial Specialist | American Institute of Certified Public Accountants | Yes |
| CIMA — Certified Investment Management Analyst | Investment & Wealth Institute | Yes |
| MSFS — Master of Science in Financial Services | Not named in the Model Rule | Yes — see below |
NASAA's two documents disagree about the MSFS
The two documents are both current and both NASAA’s, and they do not agree. The 2025 Exams FAQ lists "Chartered Financial Consultant ("ChFC") or Master of Science in Financial Services ("MSFS") awarded by the American College, Bryn Mawr, Pennsylvania". The Model Rule as amended 18 December 2024 lists only "Chartered Financial Consultant ("ChFC") awarded by The American College of Financial Services" — the MSFS does not appear in it.
We are not in a position to say which document governs in your state, and we are not going to guess. If your waiver depends on an MSFS rather than a ChFC, that discrepancy is a specific, concrete question to put to your state administrator in writing before you file.
How you claim the waiver
The mechanism is a checkbox, not an application. Per NASAA's 2025 FAQ: "The Form U4 has a box in Section 8 that should be checked indicating the certification that you hold. The CRD system then checks databases of all active certificants prepared by the certifying organizations. You may want to verify your status with the organization prior to registering."
That last sentence is the one to act on. The CRD check is automated against the certifying body's own active-certificant list, so an administrative lapse on their side — an unpaid renewal, a CE deficiency not yet cleared — surfaces as a failed waiver at filing time rather than as a warning beforehand.
What the waiver does not do
Three limits, each stated in the source rather than inferred.
It does not waive the Series 66. NASAA's FAQ is explicit: "having a qualifying professional designation will only waive the Series 65 requirement. That is because passing the Series 66 is equivalent to having passed both the Series 63 and Series 65." The same FAQ adds that "Having a valid FINRA Securities Industry Essentials Exam and Series 7 Exam are also co-requisites for registering using the Series 66."
It does not complete your registration. The waiver removes an exam requirement. Background checks, filing fees and the rest of the state's process are untouched by it.
It is not automatic in every state. This is a model rule: each jurisdiction adopts, modifies or declines it on its own timetable, and the FAQ tells you so directly — "Check with the applicable state securities administrator for details on that state's policies and to confirm whether they accept the updated professional designations as a substitute for the Series 65 exam." A state that has not yet adopted the May 2024 amendment may still be working from the older list.
If you do not hold a qualifying designation
Then the exam is the route, and the exam gate itself is open: FINRA states there are no prerequisite or corequisite exams for the Series 65, so no sponsoring firm and no earlier exam stands between you and a sitting.
| Item | Series 65 | Source |
|---|---|---|
| Prerequisite or corequisite exams | None | FINRA Series 65 exam page |
| Questions | 130 scored, plus 10 unscored pretest items | FINRA Series 65 exam page |
| Time limit | 180 minutes | FINRA Series 65 exam page |
| Passing standard | 92 of 130 scored questions | NASAA Exams FAQ, 14 Feb 2025 |
| Exam fee | $187 | FINRA Series 65 exam page |
| Retake wait | 30 days after a first or second failure; 180 days after a third within two years | NASAA Exams FAQ, 14 Feb 2025 |
Note the passing standard carefully. NASAA answers a question it evidently receives often — "Why did I receive a 'fail' on my Series 65 exam even though I scored a 70%?" — with: "The passing grade for the Series 65 exam is not 70% and is not calculated as a percentage. Candidates must answer 92 out of 130 questions correct to earn a passing grade." 92 of 130 is 70.8%, so the widely repeated "70%" is not merely imprecise, it is below the line.
To see where you actually stand against the 92-of-130 standard before you pay anything, work through a free Series 65 practice exam under full timed conditions.
The route in order, whichever one applies to you
- Decide which requirement you are actually meeting. The Series 65 and the Series 66 are different obligations with different waivers. No designation waives the Series 66.
- If you hold a designation, verify it is current and in good standing. The Model Rule sets both conditions at the time of filing. Check with the granting organization, not with your own records.
- Ask your state administrator whether they have adopted the May 2024 list. Do this before you pay for anything. NASAA's own FAQ sends you here, and for a CIMA or CIC holder it is the whole question.
- If you are sitting the exam, book it. FINRA states there are no prerequisite or corequisite exams, so nothing blocks enrollment. The fee is $187.
- Sit 140 questions in 180 minutes, 130 of them scored.
- Score against 92 of 130, not against a percentage.
- If you do not pass, count the wait. 30 days after a first failure and 30 again after a second, under NASAA’s published periods; 180 days once three attempts within two years are behind you. If your start date is fixed, book the first sitting early enough to absorb one failure.
- Complete registration with the state. Passing an exam and being registered are separate events, and a waiver only ever addresses the first.
- Start annual CE once registered. NASAA's IAR continuing-education FAQ sets 12 credits a year, split six Products and Practice and six Ethics and Professional Responsibility. Which states have adopted that requirement, and how a mid-year registration prorates, are not settled by the documents cited here — confirm with your administrator.
What we could not establish
Stating these plainly is more useful than filling them with plausible text.
Which states have adopted the May 2024 amendment. NASAA publishes the model rule; adoption is a jurisdiction-by-jurisdiction act and NASAA's own FAQ directs you to the state administrator to confirm it. We have not surveyed the states and we do not report a count.
Whether the MSFS is accepted where you are. See the discrepancy above. NASAA's two current documents differ.
What happens to someone who registered under the old list. Nothing in the cited documents addresses transition treatment for an existing registrant who qualified via a CIC before May 2024. That is a question for the administrator that granted the registration.
Fees and formats change. The $187 fee and the 130/10/180 structure are as FINRA states them on the pages cited. Confirm them on the administering authority's own page on the day you register — a figure repeated in a third-party article, including this one, is not evidence that it is still current.
I passed the Series 65 on the path that led to my CFP® certification. My biggest do-over lesson from these exams: start timed, full-length simulations early and dig weak chapters out properly — a late surge of question volume is a poor substitute for either.
Vincent Ruan, EA, CFP® · scope and limits in the full disclosure
Free Series 65 practice test — 137 questions, instant feedback. No signup required.
Sources
- 1.NASAA Model Rule: Examination Requirements for Investment Adviser Representatives — NASAA (accessed Aug 29, 2026)
- 2.NASAA Exams FAQ (updated 14 February 2025) — NASAA (accessed Aug 29, 2026)
- 3.NASAA Exams FAQ (2022, superseded) — NASAA (accessed Aug 29, 2026)
- 4.Series 65 Exam Overview — FINRA (accessed Aug 29, 2026)
- 5.IAR Continuing Education FAQ — NASAA (accessed Aug 29, 2026)
Frequently asked questions
Which professional designations waive the Series 65 exam?
Under the NASAA Model Rule on Examination Requirements for Investment Adviser Representatives (adopted 18 September 2022; amended 6 May 2024 and 18 December 2024), the exam requirement is waived for holders of the CFP, ChFC, CFA, PFS or CIMA who are \u201ccurrent and in good standing\u201d at the time they file. NASAA's Exams FAQ updated 14 February 2025 lists the same five and additionally names the MSFS. Adoption is state by state, so confirm with your state securities administrator.
Does the CIC still waive the Series 65?
It is not in the current list. NASAA's 2022 Exams FAQ named \u201cCIC \u2013 Chartered Investment Counselor (granted by the Investment Adviser Association)\u201d; neither the 2025 Exams FAQ nor the current Model Rule includes it, and the 2025 FAQ states the designations \u201cwere updated and approved by the NASAA Membership in May of 2024.\u201d Many third-party articles still publish the older list. If your plan depends on a CIC, ask your state administrator directly.
Does a designation also waive the Series 66?
No. NASAA's Exams FAQ states that \u201chaving a qualifying professional designation will only waive the Series 65 requirement. That is because passing the Series 66 is equivalent to having passed both the Series 63 and Series 65.\u201d The FAQ adds that a valid SIE and Series 7 are co-requisites for registering using the Series 66.
How do I claim the waiver?
Per NASAA: \u201cThe Form U4 has a box in Section 8 that should be checked indicating the certification that you hold. The CRD system then checks databases of all active certificants prepared by the certifying organizations.\u201d Because that check is automated against the granting body's active-certificant list, NASAA advises verifying your status with the organization before you register.
Is the Series 65 passing score 70%?
No. NASAA states that \u201cthe passing grade for the Series 65 exam is not 70% and is not calculated as a percentage. Candidates must answer 92 out of 130 questions correct to earn a passing grade.\u201d 92 of 130 is 70.8%, so a candidate targeting exactly 70% is aiming below the line.