CIMA Designation Now Exempts You from the Series 65 Exam
CIMA Designation Now Exempts You from the Series 65 Exam
CIMA Designation Now Exempts You from the Series 65 Exam
A major registration barrier just got easier for many investment professionals. In May 2024, the North American Securities Administrators Association, known as NASAA, voted to add the Certified Investment Management Analyst designation to its model rule list of credentials that can qualify for a Series 65 exam waiver.
That is big news if you hold the CIMA designation and plan to register as an investment adviser representative. It means the credential may allow you to skip the Series 65 exam, depending on the state where you register.
The key word is may. NASAA’s model rule is not self-executing in every jurisdiction. States still need to adopt the change into their own rules, and that process does not happen everywhere at the same time.
Here is what changed, what still has to happen, and how to approach the waiver without making an expensive registration mistake.
NASAA added CIMA to its Series 65 waiver model rule
NASAA maintains model rules that state securities regulators can use when setting registration standards. One of those rules addresses when an individual may be exempt from taking the Series 65 examination, formally known as the Uniform Investment Adviser Law Examination.
In May 2024, NASAA voted to amend its model rule and add the CIMA designation to the list of credentials that can support an exam waiver.
That change matters for two reasons.
It recognizes CIMA as a qualifying professional credential.
The waiver list has long included well-known designations such as the Certified Financial Planner certification, the Chartered Financial Analyst charter, and the Chartered Financial Consultant designation. Adding CIMA places it among a small set of credentials that regulators view as sufficient, in the right circumstances, to replace the Series 65 exam requirement.
It was the first new addition in decades.
The CIMA credential had not previously been on the model waiver list. According to the industry discussion around the change, this was the first new designation added to the NASAA model waiver list in 24 years. That makes the update more than a minor technical edit.
The change also came after the Chartered Investment Counselor designation, often called CIC, was discontinued. In practical terms, CIMA now occupies a place that helps modernize the waiver list for today’s investment advisory field.
The waiver is based on state adoption, not NASAA alone
The most common source of confusion is the difference between a model rule and a state rule.
NASAA does not directly license every investment adviser representative. State securities regulators handle registration within their own jurisdictions. NASAA can approve a model rule, but each state must decide how and when to adopt that rule into its own regulatory framework.
That creates a transition period.
Some states may update their rules quickly and begin recognizing CIMA for the Series 65 waiver. Other states may take longer. A few may still show older rule language for a period of time, including references to CIC rather than CIMA.
That does not always mean the state will reject the waiver. It does mean you need to verify the rule before assuming the waiver applies.
Why older designations are treated more consistently
Credentials such as CFP, CFA, ChFC, and PFS have appeared on the waiver list for many years. Because they have been part of the model rule for so long, most state processes already recognize them.
CIMA is different because the change is new. State systems, application instructions, online forms, examiner checklists, and published rules may not all update on the same timeline.
That is why two CIMA holders in two different states may have different experiences during the rollout. One may receive a waiver with little delay. Another may need to provide extra documentation or wait for the state to formally adopt the new language.
What “rolling adoption” means in practice
During a rolling adoption period, the waiver can feel uneven across the country. That is normal when a model rule changes.
A state may fall into one of several practical categories:
State status | What it may mean for a CIMA holder |
The state has adopted the updated language | CIMA may be accepted as a qualifying exam waiver credential |
The state is reviewing the change | The waiver may not be available yet, or staff may handle requests case by case |
The state rule still lists older credentials | CIMA may not appear in the written rule even if an update is expected |
The state has state-specific conditions | A waiver may require proof of good standing, active status, or other documentation |
Do not rely only on a summary article, a colleague’s experience, or an online forum. The controlling rule is the one used by the state where registration is being sought.
What the Series 65 waiver can do for CIMA holders
The Series 65 exam is commonly required for individuals who provide investment advice and register as investment adviser representatives, often shortened to IARs. It tests legal, regulatory, ethical, and investment-related knowledge.
For a CIMA holder, the new waiver can offer a meaningful practical benefit. It may remove the need to:
Schedule and sit for the Series 65 exam
Spend weeks reviewing exam prep material
Pay exam-related costs
Delay registration while waiting for testing availability
Retake the exam after an unsuccessful attempt
That can be especially helpful for experienced professionals who already maintain a demanding credential and need to complete state registration without duplicating education and testing.
The waiver does not mean regulators view the Series 65 as unimportant. It means NASAA has determined that certain professional credentials may satisfy the exam requirement when the credential is current and the state recognizes it.
What the waiver does not exempt you from
This point deserves extra attention. A Series 65 waiver is not the same as a license. It is not a blanket approval to give investment advice for compensation.
The waiver addresses one part of the registration process: the examination requirement.
A CIMA holder may still need to complete several other steps before acting as an investment adviser representative.
You still need to register where required
If your role requires IAR registration, you still need to file through the proper regulatory system, usually through the firm’s registration process. The filing may involve Form U4 and related state registration steps.
The waiver may remove the exam requirement, but it does not remove the need to be properly registered.
You still need to meet state and firm requirements
States may review disciplinary history, disclosures, prior registrations, and other information. Firms may also have internal policies that go beyond state minimums.
For example, a firm may still require certain exams, training, or compliance approvals before allowing a representative to provide advisory services.
You still need to keep the CIMA credential active
A waiver generally depends on holding the qualifying designation in good standing. If the credential lapses, becomes inactive, or is subject to disciplinary issues, the waiver may not be available.
Keep documentation current. That may include proof of active CIMA status and any continuing education records required by the credentialing body.
You may still need other securities exams
The Series 65 is tied to investment adviser representative qualification. It does not replace every securities exam or registration category.
If a role also involves brokerage activity, variable products, or other regulated functions, other exams or registrations may still apply. The waiver does not automatically cover broker-dealer agent registration or state law exam requirements outside the specific IAR exam context.
How to check whether your state recognizes the CIMA waiver
Before making career plans around the waiver, confirm the rule in the state or states where registration is needed.
A careful check should include more than a quick internet search.
Start with the state securities regulator
Look for the state’s investment adviser representative registration rules. In many states, those rules list acceptable professional designations for an exam waiver.
Search for terms such as:
`investment adviser representative exam waiver`
`Series 65 waiver`
`professional designation waiver`
`CIMA`
`NASAA model rule`
If the state publishes a rule that now includes CIMA, that is a strong sign the waiver is available.
If the rule still lists CIC and does not mention CIMA, do not assume the answer is no. The page may not have been updated yet, or the state may still be in the adoption process.
Ask the registration or compliance team
If you work with a registered investment adviser, broker-dealer, or hybrid firm, the internal registration team may already know how each state is handling the CIMA waiver.
This is especially useful for firms that register representatives in many states. They may have current notes from recent filings, state examiner feedback, or internal guidance on where the waiver is being accepted.
Confirm before filing if the answer is unclear
When a state’s published rule is not clear, ask for confirmation before submitting an application that depends on the waiver. That can help avoid delays, deficiency notices, or the need to schedule an exam unexpectedly.
A short written confirmation from the state or a documented note from compliance can save time later.
What documentation to have ready
The exact documentation can vary by state and firm, but CIMA holders should be prepared to prove that the credential is valid and current.
Useful records may include:
Proof of active CIMA designation status
Evidence that the credential is in good standing
Continuing education completion records, if requested
Full legal name matching registration records
Any supporting form required by the firm or state
Keep copies organized before the registration filing begins. The waiver may be simple in states that have already adopted the rule, but missing documentation can still slow the process.
If your name has changed since earning the designation, make sure your registration filing, credential records, and identification records align. Small mismatches can create unnecessary back-and-forth.
Why this change matters for the advisory profession
The addition of CIMA to the waiver list reflects a broader shift in how professional credentials fit into adviser regulation.
The advisory field has grown more specialized. Many professionals work in portfolio construction, investment consulting, due diligence, manager selection, retirement plan advisory work, or wealth management. The CIMA program is closely tied to investment management and advisory practice, so its inclusion on the waiver list gives regulators another way to recognize advanced professional preparation.
For CIMA holders, the change can make career moves easier. A professional moving into an IAR role may not need to start from scratch with the Series 65 if the state recognizes the waiver.
For firms, the change may reduce onboarding friction. If a candidate already holds CIMA in good standing, the registration timeline may be shorter in states that have adopted the updated rule.
For clients, the main benefit is indirect. The waiver does not guarantee competence, ethics, or good advice. No credential can do that by itself. Still, recognizing established professional designations can support a registration system that accounts for meaningful education and experience.
Common mistakes to avoid
The CIMA waiver is helpful, but it is easy to overread the change. Avoid these mistakes.
Assuming NASAA approval means every state is ready
The model rule is the starting point. State adoption is the controlling step.
Before relying on the waiver, check the state rule or get confirmation from the regulator or compliance team.
Treating the waiver as automatic registration
The waiver does not register anyone. It only addresses the examination requirement. You still need a proper filing and approval where required.
Letting the credential lapse
A lapsed designation may not support a waiver. Keep the CIMA designation active and maintain good standing.
Ignoring multi-state registration issues
If you need to register in more than one state, check each state separately. One state’s acceptance does not bind another state.
Waiting until the last minute
If a state has not clearly adopted the change, the waiver request may take extra time. Build that into any job transition, firm onboarding, or advisory launch plan.
A practical checklist for CIMA holders
Before deciding to skip the Series 65 exam, work through this checklist:
Confirm your CIMA status
Make sure the designation is active and in good standing.
Identify every state involved
Include your home state, the firm’s registration states, and any state where IAR registration may be required.
Check each state’s current rule
Look for updated waiver language that includes CIMA.
Ask compliance to verify
If you are affiliated with a firm, get their registration team involved early.
Prepare proof of designation
Have current documentation ready before filing.
Do not begin advisory activity until approved
Wait until the registration process is complete and your firm clears you to act in the role.
This is the safest way to use the new waiver without creating a compliance problem.
The bottom line for CIMA holders
The CIMA designation has now been added to NASAA’s model rule list for Series 65 exam waivers, marking a significant change for investment professionals. For many CIMA holders, that means the path to IAR registration may become faster and less exam-heavy.
The nuance matters. NASAA’s action does not instantly rewrite every state rule. States must adopt the change, and adoption can happen on different timelines.
If your state recognizes the updated rule and your CIMA designation is active and in good standing, you may be able to avoid the Series 65 exam. If your state has not adopted the change yet, you may need to wait, provide more documentation, or take the exam under the current rule.
Treat the waiver as a strong opportunity, not a shortcut around compliance. Verify the state rule, document your credential, and make sure registration is complete before acting as an investment adviser representative.
This post is for general informational purposes only and is not legal, regulatory, or financial advice. Consult your firm’s compliance team or the relevant state securities regulator for guidance on a specific registration situation.
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