New York RA/IAR registration and exam waiver pack

Route focus

A New York RA registration file should prove who must register, which examination or waiver route applies, whether Form U4 data and CRD records support the route, and whether the applicant can advise, supervise, or solicit before approval.

Who this helps

• - Investment adviser representatives seeking New York RA registration
• - RIA founders, principals, supervisors, and solicitors checking New York individual-registration requirements
• - Compliance teams preparing Form U4, waiver, disclosure, and CRD support for New York registrations
• - Series 65, Series 66, Series 7, and SIE/S7TO candidates who need state-specific New York exam timing context

Licence scope

• - Map whether the person is an investment adviser representative, principal, supervisor, solicitor, or solicitor-firm person under New York's RA registration framework.
• - Separate New York firm Form ADV registration or notice filing from individual RA registration through Form U4.
• - Check Series 65 timing, Series 66 timing, valid Series 7 or SIE/S7TO status, professional or prior-registration waiver assumptions, special waiver eligibility, and disclosure-history caveats.
• - Treat New York as a special state page because its RA registration and waiver guidance is more specific than a generic NASAA Series 65/66 note.

Pre-draft questions

• - Is the person associated with a New York state registered adviser, federally covered adviser, solicitor firm, or other advisory business that triggers RA registration?
• - Is the person acting as an IAR, solicitor, principal, supervisor, or person associated with a solicitor firm?
• - Was Series 65 passed within two years, or was Series 66 passed within two years with valid Series 7 or SIE/S7TO status on CRD?
• - Does the applicant qualify for a waiver under 13 NYCRR 11.7(a), a special waiver under 11.7(b), or another route requiring Form NY-IASW or disclosure support?
• - Do Form U4 disclosures, CRD employment/affiliation history, customer complaint/arbitration/civil/regulatory history, and exam records support the selected route?

Evidence pack

People and governance

• - New York principals, supervisors, solicitors, and investment adviser representatives should not rely on job title alone; the RA trigger depends on actual activity and firm context.
• - A valid Series 7 or SIE/S7TO can matter for Series 66 analysis, but New York still focuses on Series 65 or Series 66 timing and CRD records.
• - Waiver support should be treated as an evidence pack, not a casual checkbox, especially where disclosures or registration gaps exist.
• - Compliance should decide who monitors Form U4 amendments, outside business activities, public titles, and solicitation controls after approval.

Forms and submission

• - Use Form U4 through CRD to request NY RA registration and keep the firm's Form ADV or solicitor-firm context in the same evidence file.
• - For exam qualification, document Series 65 within two years, or Series 66 within two years together with valid Series 7 or SIE/S7TO status, unless a waiver applies.
• - For waiver routes, prepare 13 NYCRR 11.7 support, Form NY-IASW where relevant, CRD affiliation evidence, and disclosure explanations before submission.
• - After approval, verify public records and keep U4 amendment, waiver, disclosure, outside activity, and termination controls current.

Timeline risks

• - New York timing problems often arise from old Series 65 or Series 66 results, unclear valid Series 7/SIE/S7TO status, or waiver assumptions that do not match CRD records.
• - Disclosure history can affect waiver analysis; the New York guidance focuses on civil/regulatory actions, proceedings, and arbitrations requiring Form U4 disclosure.
• - Opening or declining an exam window incorrectly can materially delay registration if the applicant does not qualify for the selected waiver path.
• - Solicitor, principal, supervisor, and special-waiver facts should be resolved before client-facing activity is planned.

Questions to ask advisers

• - Is the person an RA/IAR, principal, supervisor, solicitor, or solicitor-firm person under New York's framework?
• - Is Series 65, Series 66 plus valid Series 7 or SIE/S7TO, or a waiver the correct evidence route?
• - Does the Form U4 disclosure record create waiver risk or require additional explanation before submission?
• - What client-facing, supervisory, or solicitation activity must pause until New York RA registration is granted?

Common mistakes

• - Assuming New York follows a generic state IAR rule without checking the RA registration and waiver guidance.
• - Treating a valid Series 7 alone, SIE alone, or old Series 65/66 pass as automatically enough for New York.
• - Ignoring principals, supervisors, solicitors, and solicitor-firm persons who may need RA registration analysis.
• - Submitting a waiver request without CRD affiliation, Form U4 disclosure, exam-date, and continuous-registration support.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.