What Can You Do With a Series 65 License?

A Series 65 license lets you work as an investment adviser representative giving personalized investment advice for a fee, charge clients directly under arrangements like a percentage of assets under management, and register your own firm as a registered investment adviser (RIA). What it does not do is authorize you to execute trades or earn commissions. So the question of what you can do with a Series 65 license really has two answers: the fee-based advisory work it opens up, and the fiduciary obligations that come attached to that work.

Jobs the License Qualifies You For

The most common role is investment adviser representative at an existing advisory firm. In that seat you manage client relationships, recommend portfolio allocations, and provide ongoing guidance on market conditions and financial planning. Many firms require the Series 65 (or the Series 66 alternative) for titles like wealth manager, portfolio manager, and financial planner. These positions center on building long-term strategies aligned with a client’s risk tolerance, time horizon, and financial goals.

Some license holders work as research analysts inside advisory firms, producing market analysis and investment reports that other advisers use when making recommendations. Others serve as promoters, the current regulatory term for individuals who refer prospective clients to an adviser in exchange for compensation. Under the SEC’s Marketing Rule, a promoter’s arrangement must be documented in a written agreement, and the adviser must ensure the promoter discloses to each prospect that compensation is being paid, the material terms of that compensation, and any conflicts of interest arising from the relationship.1eCFR. 17 CFR 275.206(4)-1 – Investment Adviser Marketing Older materials sometimes call this role a “solicitor,” but the SEC replaced the cash solicitation rule with the broader Marketing Rule, and the promoter framework now governs these arrangements.2U.S. Securities and Exchange Commission. Investment Adviser Marketing

One important caveat: passing the exam does not by itself authorize you to do business. You still have to register in the state where you plan to work before taking on clients.3North American Securities Administrators Association. Series 65 Exam Content Outline

How You Can Get Paid

The license lets you charge clients directly for investment advice, which is the defining feature of the investment adviser model. Federal law defines an investment adviser as anyone who, for compensation, is in the business of advising others about the value of securities or the advisability of buying or selling them.4Office of the Law Revision Counsel. 15 USC 80b-2 – Definitions

The most common fee arrangement is a percentage of assets under management. According to NASAA’s guidance on advisory fees, AUM-based fees typically run from 0.5% to about 3% per year, though fees above 2% are considered unreasonable in many jurisdictions and may violate an adviser’s fiduciary duties. You can also charge hourly rates for financial planning consultations or flat fees for discrete projects like building a comprehensive plan. Whichever model you use, the fee structure must be clearly disclosed in both your Form ADV brochure and your written client agreement.5NASAA. Investment Adviser Section, Regulatory Policy and Review Project Group Fee Guidance

Performance-Based Fees for Qualified Clients

The law also allows performance-based compensation, but only for “qualified clients.” Under SEC rules, a qualified client must have at least $1,100,000 in assets under the adviser’s management or a net worth exceeding $2,200,000, excluding the value of a primary residence.6U.S. Securities and Exchange Commission. Inflation Adjustments of Qualified Client Thresholds These thresholds are adjusted for inflation roughly every five years, with the next adjustment scheduled for on or about May 1, 2026.7eCFR. 17 CFR 275.205-3 – Exemption From the Compensation Prohibition of Section 205(a)(1) for Investment Advisers

The Fiduciary Duty You Take On

This is where the Series 65 path fundamentally differs from working as a broker-dealer agent. Investment advisers owe their clients a fiduciary duty rooted in Section 206 of the Investment Advisers Act, which prohibits advisers from employing any scheme to defraud a client or engaging in any practice that operates as fraud or deceit.8Office of the Law Revision Counsel. 15 USC 80b-6 – Prohibited Transactions by Investment Advisers Courts and the SEC have interpreted those anti-fraud provisions as creating both a duty of care and a duty of loyalty that apply throughout the entire advisory relationship, not just at the moment of a recommendation.9U.S. Securities and Exchange Commission. Regulation Best Interest and the Investment Adviser Fiduciary Duty

Broker-dealer representatives, by contrast, operate under Regulation Best Interest, which requires them to act in a retail customer’s best interest at the time of a recommendation but does not impose an ongoing monitoring obligation. The adviser fiduciary duty is broader: an adviser must serve the client’s best interest at all times and cannot satisfy that obligation through disclosure alone.9U.S. Securities and Exchange Commission. Regulation Best Interest and the Investment Adviser Fiduciary Duty

What the License Does Not Let You Do

The boundaries catch some people off guard. A Series 65 holder cannot execute securities trades or earn commissions on transactions. The license qualifies you to advise, not to sell. If a client needs someone to place a buy or sell order, that trade flows through a broker-dealer, and your compensation stays fee-based.

This limitation matters most if you want to do both: give advice and execute trades. For that you would need either the Series 7 combined with the Series 66, or the Series 7 alongside the Series 65. The Series 66 is essentially a condensed version of the Series 65 combined with the Series 63 state law exam, but it requires the Series 7 as a co-requisite and must be taken through a FINRA member firm. If you only want to provide fee-based advice and have no interest in transaction-based compensation, the standalone Series 65 is the simpler and more direct path.

Starting Your Own RIA Firm

For license holders who want to build their own practice, the Series 65 is the prerequisite for registering a firm as a registered investment adviser. The process starts with Form ADV, which the SEC and state regulators use as the universal registration and disclosure document.10SEC.gov. Form ADV – General Instructions

Form ADV Part 1 and Part 2

Part 1 collects operational information about the firm: ownership structure, direct owners and executive officers, the number of employees, types of advisory services offered, and total regulatory assets under management. It also requires a disciplinary history through Disclosure Reporting Pages, which ask about any legal or regulatory events involving the firm or its advisory affiliates.10SEC.gov. Form ADV – General Instructions

Part 2 is the client-facing document. It must be written as a narrative brochure describing the firm’s services, fee schedules, investment strategies, and any conflicts of interest such as relationships with broker-dealers or compensation arrangements with third parties.11U.S. Securities & Exchange Commission. How To Register as an Investment Adviser You file both parts and all applicable schedules through the Investment Adviser Registration Depository (IARD) system.12U.S. Securities and Exchange Commission. Electronic Filing for Investment Advisers on IARD

State or SEC Registration

Where you register depends on how much money your firm manages. Firms with less than $100 million in assets under management generally register with their home state’s securities regulator. Once a firm reaches $100 million it may register with the SEC, and at $110 million it must do so. There is a buffer: once SEC-registered, a firm does not need to withdraw and switch back to state registration until its AUM drops below $90 million.13eCFR. 17 CFR 275.203A-1 – Eligibility for SEC Registration; Switching to or From SEC Registration

Most new RIAs start at the state level because they launch with far less than $100 million in client assets. State fees vary. Even SEC-registered firms must still make notice filings with the states where they operate. For SEC registration, the agency generally has 45 days after receiving your Form ADV to declare the registration effective.12U.S. Securities and Exchange Commission. Electronic Filing for Investment Advisers on IARD

What You Have To Keep Doing Once Licensed

Running an RIA comes with continuing obligations that many new advisers underestimate.

Every registered investment adviser must designate a chief compliance officer responsible for administering the firm’s compliance policies and procedures. The CCO must be a supervised person within the firm.14eCFR. 17 CFR 275.206(4)-7 – Compliance Procedures and Practices For a solo practitioner, that means you are the CCO. The role involves adopting written policies designed to prevent violations of the Investment Advisers Act, reviewing those policies at least annually, and documenting that review.

Federal rules require advisers to keep all written communications related to investment recommendations, fund transfers, and trade orders. These records must be preserved for at least five years from the end of the fiscal year in which the last entry was made, with the first two years kept in an accessible office location. Electronic storage is permitted, but the firm must have procedures to safeguard the records from loss or alteration and to limit access to authorized personnel.15eCFR. 17 CFR 275.204-2 – Books and Records To Be Maintained by Investment Advisers

States that have adopted NASAA’s model rule on IAR continuing education require each registered representative to complete 12 credits annually: six in ethics and professional responsibility, and six in products and practice.16North American Securities Administrators Association. IAR CE Requirements Overview Not every state has adopted the requirement yet, so check your state’s rules. FINRA also offers an Eligible Voluntary Exam Program that lets individuals who leave the industry maintain the validity of their Series 65 results for up to five years by completing annual CE.17FINRA. Series 65 – Uniform Investment Adviser Law Exam

Firm registrations must be renewed annually through the IARD. For the 2026 renewal cycle, the last day to submit filings is December 26, with the final payment deadline on January 23.18IARD. 2026 Investment Adviser Renewal Program Missing these deadlines can lapse your registration, which means you cannot legally advise clients until the renewal is processed.

When You Can Skip the Exam

You do not always need to take the Series 65. NASAA’s model rule recognizes several professional designations as equivalent, waiving the exam requirement for holders in good standing:

Individual states decide which waivers they accept, so holding one of these designations does not guarantee an automatic waiver everywhere. Confirm with your state securities regulator before relying on a waiver instead of sitting for the exam.