FINRA vs NASAA Exams: How the Securities License Structure Works

8/17/2026

Most people meet the securities licensing system as a list of numbers: Series 6, 7, 63, 65, 66, 24. Lists like that hide the structure underneath, and the structure is what tells you which exams you actually need, in what order, and who has to sign off before you can take them.

There are really two systems layered on top of each other. FINRA runs the qualification exams that let a person register with a broker-dealer. NASAA, the association of state and provincial securities regulators, writes the state law exams that the states use for their own registrations. FINRA administers both kinds of exam, which is why the two get blurred together, but they answer to different regulators and serve different purposes.

This guide maps the whole structure in one place, from the SIE and the top-off exams through the principal level and the NASAA state exams, and then shows where bank employees fit, including the large group of branch staff who work alongside an investment program without ever registering.

Two Regulators, One Testing System

FINRA: registration with a broker-dealer

FINRA is the self-regulatory organization for broker-dealers. If you work for a FINRA member firm and engage in securities business, you must be registered with FINRA in the category that matches your activities, and you qualify for that registration by passing the corresponding exam. Your firm files a Form U4 through the Central Registration Depository, which both requests the exam and, once you pass, registers you.

FINRA exams are organized into levels:

• The SIE, a general knowledge exam open to anyone aged 18 or older.
• Representative-level top-off exams, which require firm sponsorship and qualify you for a specific representative category.
• Principal-level exams, which qualify you to supervise.

FINRA also administers exams written by other bodies: the MSRB for municipal securities, the NFA for futures, and NASAA for state securities law.

NASAA: registration with the states

State securities regulators register the agents of broker-dealers and the representatives of investment advisers who do business in their states. The NASAA model exams give the states a uniform way to qualify those people. FINRA describes each of them as a NASAA exam administered by FINRA.

The three NASAA exams that matter to most candidates are:

• Series 63, Uniform Securities Agent State Law Exam. Qualifies a broker-dealer agent on state securities law.
• Series 65, Uniform Investment Adviser Law Exam. Qualifies an investment adviser representative.
• Series 66, Uniform Combined State Law Exam. Combines agent and adviser representative state law, for candidates who also hold the Series 7.

A representative at a broker-dealer typically needs both a FINRA registration and a state registration in each state where they do business. The FINRA exam qualifies them for the first, and the NASAA exam, where the state requires one, qualifies them for the second.

The FINRA Structure: SIE Plus Top-Off

Since October 1, 2018, FINRA's representative qualification has worked in two parts. The SIE covers general industry knowledge, and a top-off exam covers the specialized functions of the role. FINRA calls the SIE a corequisite to the representative exams: you must pass both to hold the registration, though not necessarily in a particular order.

The same restructuring retired several older exams. FINRA stopped offering the Series 11, Series 17/37/38, Series 42, Series 62 and Series 72 on October 1, 2018. People who held those registrations at the time could keep them unless they let them lapse for two years or more. If you see the Series 62 (Corporate Securities Representative) in an older job description or an old study guide, that is why: it no longer exists as an exam a new candidate can take.

Representative-level exams

FINRA's current list of representative-level exams is:

Exam	Registration	Typical bank-world use
Series 6	Investment Company and Variable Contracts Products Representative	Platform representatives selling mutual funds and variable annuities
Series 7	General Securities Representative	Full-service representatives and financial advisors
Series 22	Direct Participation Programs Limited Representative	Rare in banks
Series 57	Securities Trader Representative	Trading desks
Series 79	Investment Banking Representative	Capital markets and M&A advisory groups
Series 82	Private Securities Offerings Representative	Private placement activity
Series 86/87	Research Analyst	Research groups
Series 99	Operations Professional	Brokerage operations staff touching customer assets

 

For most bank investment programs, the decision is between the Series 6 and the Series 7. The Series 6 covers packaged products, which is the core of many branch-based programs. The Series 7 covers the general range of securities, including individual stocks, bonds and options, and it is the corequisite for the Series 66 and the base for several principal exams. FINRA lists the Series 7 at 125 scored questions over 3 hours and 45 minutes, against 50 questions over 1 hour and 30 minutes for the Series 6, which gives a sense of the difference in scope.

Principal-level exams

Supervisors need a principal registration. FINRA's principal-level list includes the Series 4 (Registered Options Principal), Series 9/10 (General Securities Sales Supervisor), Series 14 (Compliance Officer), Series 16 (Supervisory Analyst), Series 23 (General Securities Principal, Sales Supervisor Module), Series 24 (General Securities Principal), Series 26 (Investment Company and Variable Contracts Products Limited Principal), Series 27 (Financial and Operations Principal), Series 28 (Introducing Broker-Dealer Financial and Operations Principal) and Series 39 (Direct Participation Programs Limited Principal).

In a bank setting the common pairings are:

• Series 26 above a Series 6 program. A sales manager supervising funds-and-annuities representatives.
• Series 24 above a Series 7 program. The general principal registration.
• Series 9/10 for sales supervision in a branch-office structure, an alternative firms consider depending on the supervisor's responsibilities.
• Series 27 for the financial and operations principal of the broker-dealer itself.

Principal exams generally require the matching representative registration as a prerequisite, so the representative exam always comes first.

The other SROs' exams that FINRA delivers

FINRA administers the MSRB's municipal securities exams (Series 50, 51, 52, 53 and 54) and the NFA's futures exams (including the Series 3, 30, 31, 32 and 34). A bank broker-dealer with a municipal underwriting desk will care about the MSRB set. A bank whose affiliate solicits futures business will need the NFA side. Most branch-based investment programs need neither.

The NASAA Structure: State Law Exams

The NASAA exams test state securities law and ethics, not products. They are shorter than the Series 7, and the 65 and 66 are substantial in their own right. Here is how FINRA lists them as of October 2026:

Exam	Scored questions	Time	Passing	Corequisite
Series 63	60 (plus 5 unscored)	75 minutes	43 of 60	None
Series 65	130 (plus 10 unscored)	180 minutes	92 of 130	None
Series 66	100 (plus 10 unscored)	150 minutes	73 of 100	Series 7 (and the SIE)

 

Series 63: the agent exam

The Series 63 qualifies a broker-dealer agent under state law. Many states require it in addition to the FINRA representative registration, which is why the classic combination for a new representative is the SIE, the Series 6 or 7, and the Series 63. Requirements vary by state, so the firm's registration team will confirm which states need it for a given representative.

Series 65: the adviser exam

The Series 65 qualifies an investment adviser representative, someone who gives investment advice for compensation on behalf of a registered investment adviser rather than earning commissions as a broker-dealer agent. It has no prerequisite. NASAA's guidance is that candidates who are not affiliated with a firm can open an enrollment window through FINRA's Test Enrollment Services System, which is why the Series 65 is often described as an exam you can take without a sponsor.

Series 66: the combined exam

The Series 66 covers both the agent and adviser representative state law material in one exam, but only for candidates who also hold the Series 7. FINRA lists the Series 7 as a corequisite. NASAA's guidance adds that the tests can be taken in any order, provided both, along with the SIE, are passed at the time you seek state registration. A candidate without the Series 7 who needs both state qualifications takes the 63 and 65 separately.

NASAA result validity

NASAA's rule is that once you pass an exam, you have two years to become registered with a state, or the result expires. After that, the qualification stays current as long as your state registration is active.

How the Two Systems Fit Together

The cleanest way to see the structure is to follow a few common bank roles through it.

Branch platform representative selling mutual funds and annuities.

SIE, then Series 6 sponsored by the broker-dealer running the program, then the Series 63 for the states where the representative will do business. If variable annuities are in scope, a state insurance producer license with the appropriate line of authority is also required, because a variable annuity is both a security and an insurance contract.

Financial advisor in the bank's brokerage affiliate.

SIE, Series 7, then the Series 63 or, if the advisor will also give fee-based advice through an affiliated investment adviser, the Series 66 instead of the 63 and 65 separately.

Fee-based adviser in a bank-affiliated registered investment adviser.

Series 65 on its own may be enough if the person is not also a broker-dealer representative. Adding the Series 7 and switching to the Series 66 is common for people who do both.

Branch or investment sales manager.

The representative registration that matches the program, then the Series 26 or the Series 24 (or the 9/10 pair), depending on what is being supervised.

Brokerage operations staff.

SIE and Series 99 where the role meets FINRA's operations professional definition.

Trust officers and bank fiduciary staff.

Often none. Banks are excepted from the definition of broker for certain activities, including trust and fiduciary activities conducted under the conditions in Regulation R. Whether a particular role needs registration depends on how the bank structures the activity, which is a question for the bank's compliance and legal teams.

The securities licensing for bankers post works through these roles in more depth, and the securities licensing page lists prep for every exam mentioned here.

Where Unregistered Bank Staff Fit

The largest group of bank employees connected to an investment program are those who never register at all: tellers, personal bankers and branch managers who refer customers to the investment representative. They operate under the networking exception that the Gramm-Leach-Bliley Act wrote into the definition of broker, as implemented by Regulation R.

Under that framework an unregistered bank employee may refer a customer to the broker-dealer and may receive a referral fee, but only within strict limits. Under 12 CFR 218.700 the fee must be a nominal one-time cash fee of a fixed dollar amount, and the rule gives three ways to measure "nominal": tests based on the hourly wage or base salary for the employee's job family, tests based on the employee's own hourly wage or salary, or a fixed dollar amount that is adjusted for inflation under the rule. The fee may depend on whether the customer contacts or keeps an appointment with the broker-dealer, or meets objective baseline qualification criteria, but not on whether the referral produces a transaction.

What the unregistered employee may not do is the work the exams qualify people for: recommend a security, discuss the merits of a particular investment, or take an order. A branch employee who says, "Let me introduce you to our investment representative," is inside the line. One who says, "That fund would be a good fit for you," has crossed it.

This is why the licensing structure matters even to staff who will never take an exam. The registration categories define activities, and the activities define who needs to be registered. Our post on bank investment services compliance sets out what branch staff can and cannot say in a referral.

Lapses, Retakes and Moving Between Firms

Several rules govern what happens to a qualification after you pass.

Representative and principal qualifications lapse after two years without registration. Under FINRA Rule 1210, a person last registered as a representative two or more years before a new application must requalify by exam.

The SIE has a four-year window. A person who last passed the SIE, or was last registered as a representative, four or more years before a new application must also retake the SIE.

FINRA's Maintaining Qualifications Program gives eligible people who terminate a registration a way to preserve their qualifications for up to five years by keeping up with FINRA's annual requirements, subject to the eligibility conditions FINRA sets.

NASAA exams expire two years after passing if the candidate does not register with a state, and remain valid while a state registration stays active.

Retake waiting periods apply after a failure. FINRA's current rule requires 30 days after a first or second failure and 180 days after a third failure within two years. FINRA has filed an amendment cutting those to 15 and 60 days, but the shorter periods take effect only on an implementation date FINRA will announce by Regulatory Notice. NASAA has announced its own change: its FAQ says the 180-day wait after a third failure drops to 60 days for NASAA exams effective January 4, 2027. Check the current rule before you plan a retake.

Choosing Your Path

For a bank employee, the decision tree is shorter than the exam list suggests.

1. Not yet sponsored? Start with the SIE. It is the one FINRA exam you can take on your own.
2. Joining a funds-and-annuities program? Plan for the Series 6 and the Series 63, plus an insurance license if variable annuities are sold.
3. Joining a full-service brokerage role? Plan for the Series 7 and the Series 63, or the Series 66 if fee-based advice is part of the job.
4. Moving into supervision? Add the principal exam that matches what you will supervise.
5. Staying in the branch? Learn the networking rules thoroughly, because they are the only securities rules that apply to you and examiners test them.

The Series 7 is the hinge of the whole structure. It is the broadest representative exam, the corequisite for the Series 66, and the base for the general principal exams. Our Series 7 Top-Off Online Exam Prep Course is built for candidates who have been sponsored for it.

Prep for Every Level

Whichever path your role requires, start with the exam you can take now and work up. For the broad brokerage path, the Series 7 Top-Off Online Exam Prep Course is the core of the plan; prep for the SIE, the state law exams and the principal exams is listed on the securities licensing page.

Frequently Asked Questions

What is the difference between FINRA and NASAA exams?

FINRA exams qualify a person to register with a broker-dealer in a specific activity category, such as the Series 6, Series 7 or Series 24. NASAA exams, namely the Series 63, 65 and 66, test state securities law and qualify a person for registration with state regulators as an agent or investment adviser representative. FINRA administers both kinds, which is why they are often confused, but the NASAA exams belong to the state regulatory system. Many representatives need one of each: a FINRA registration and a state law qualification.

Which FINRA series exams can I take without a sponsor?

Among FINRA's own exams, only the SIE is open without firm sponsorship; anyone aged 18 or older can enroll. The representative-level top-off exams, including the Series 6 and Series 7, require association with and sponsorship by a member firm. Among the NASAA exams, NASAA says candidates not affiliated with a firm can open an enrollment window through FINRA's Test Enrollment Services System, which is why the Series 65 is commonly taken without a sponsor by people heading into advisory work.

Do I need the Series 63 if I have the Series 7?

Usually, yes. The Series 7 qualifies you for FINRA registration as a general securities representative, but states register broker-dealer agents separately, and many states require the Series 63 as their state law qualification. The exception is a candidate who takes the Series 66 instead, which covers the agent material along with the adviser representative material and requires the Series 7. Requirements differ by state, so your firm's registration team will confirm which states need which exam.

Is the Series 62 still offered?

No. FINRA stopped offering the Series 62, along with the Series 11, 17/37/38, 42 and 72, on October 1, 2018, when it introduced the SIE and restructured the representative exams. People who held those registrations could keep them unless they let them lapse for two years or more. A new candidate who would once have taken the Series 62 for corporate securities would now generally take the SIE and the Series 7.

Can I take the Series 66 without the Series 7?

You can sit for it, but it will not qualify you on its own. FINRA lists the Series 7 as a corequisite to the Series 66, and NASAA's guidance is that you must have valid SIE and Series 7 results, as well as the Series 66, when you seek state registration. The exams can be taken in any order. A candidate who does not hold the Series 7 and needs both state qualifications takes the Series 63 and Series 65 separately instead.

Do bank tellers need a securities license to refer customers?

No, provided the referral stays within the networking exception implemented by Regulation R. An unregistered employee may refer a customer to the broker-dealer and receive a nominal, one-time, fixed-dollar referral fee that is not contingent on whether a transaction results. The employee may not recommend securities, discuss the merits of an investment or take orders. Once a conversation moves from introduction to recommendation, it is securities activity that requires registration.