SIE vs Series 65

The SIE and Series 65 represent two fundamentally different career paths in financial services. The SIE is a FINRA corequisite exam that opens the door to the broker-dealer world — you must pass it, along with the Series 7 (in either order), to sell securities on commission. The Series 65 is a NASAA exam that is a completely standalone license, requiring NO SIE and NO firm sponsorship, allowing you to work as an Investment Adviser Representative (IAR) at a fee-only RIA firm under the fiduciary standard. This is the single most important career path decision in the financial services licensing world: commissions (SIE→S7) vs. fees (S65).

Side-by-Side Comparison

Feature	SIE	Series 65
Full Name	Securities Industry Essentials Exam	Uniform Investment Adviser Law Exam
Exam Cost	$100	$187
Passing Score	70 (scaled; no fixed number correct is published)	92 of 130 scored questions correct
Questions	80 (75 scored + 5 unscored)	140 (130 scored + 10 unscored)
Time Limit	1 hour 45 minutes	3 hours
Study Time	40 - 60 hours over 2 - 4 weeks	Not published by NASAA
Difficulty	Entry-level	Moderate to Challenging
Prerequisites	None — anyone 18+ can take it without firm sponsorship	None — no SIE, no firm sponsorship, no prior licenses required. Anyone can register to take it.
Exam Body	FINRA	NASAA (North American Securities Administrators Association)

Key Differences

1The SIE is a corequisite exam with zero standalone earning power; the Series 65 is a standalone license that immediately qualifies you to work as an Investment Adviser Representative (IAR) at an RIA firm and charge fees for investment advice.
2The SIE is administered by FINRA and feeds into the broker-dealer/commission-based system; the Series 65 is developed by NASAA (FINRA administers it) and feeds into the RIA/fee-based advisory system — these are two entirely separate regulatory frameworks.
3The Series 65 does NOT require the SIE, firm sponsorship, or any prior license. Anyone can register and take it. This makes it the #1 choice for career changers who want to bypass the FINRA system entirely.
4The SIE and Series 7 path leads to broker-dealer work under Regulation Best Interest; the Series 65 path leads to a fiduciary standard (legally required to act in the client's best interest at all times).
5The SIE costs $100 with 75 scored questions in 1 hour 45 minutes; the Series 65 costs $187 with 130 scored questions in 3 hours — the Series 65 is a longer, more demanding exam.
6Revenue models differ fundamentally: the SIE→Series 7 path earns commissions on transactions; the Series 65 path earns AUM-based fees, hourly fees, or flat planning fees — recurring revenue that compounds over time.
7The SIE result is valid for 4 years and requires a subsequent top-off exam (Series 7, 6, etc.); the Series 65 license is immediately active upon passing and state registration, with no additional exams required.

What Each Exam Allows You To Do

SIE

Demonstrate foundational knowledge of the securities industry to prospective employers
Satisfy the corequisite for all FINRA representative-level registrations (Series 6, 7, 57, 79, etc.)
Signal to broker-dealer hiring managers that you are prepared and committed to a finance career
Begin the licensing pipeline at a FINRA-member firm — the SIE is step one on the broker-dealer path

Series 65

Work as an Investment Adviser Representative (IAR) at a state-registered or SEC-registered RIA firm
Provide personalized investment advice and charge fees (AUM-based, hourly, flat-fee, or financial planning fees)
Manage client portfolios on a discretionary or non-discretionary basis under the fiduciary standard
Operate as a fee-only financial planner — no commissions, no conflicts of interest, pure fiduciary advice
Serve as the qualifying individual to register your own RIA firm with your state securities regulator

Who Should Take Each Exam?

Take the SIE if you...

→People who want to work at a broker-dealer selling securities on commission
→College students targeting wirehouse training programs at Morgan Stanley, Merrill Lynch, or UBS
→Anyone planning to take the Series 7 for the full general securities license
→Job seekers who want to prove initiative to FINRA-member firms before being hired

Take the Series 65 if you...

→Career changers who want to become financial advisors without entering the FINRA broker-dealer system
→CFP candidates and fee-only financial planners who need the Series 65 for state registration
→Professionals at RIA firms (Vanguard Personal Advisor Services, Buckingham Strategic Wealth, fee-only shops)
→CPAs, attorneys, and other professionals adding investment advisory services to their existing practice
→Anyone who wants a standalone license to give investment advice — the Series 65 is the fastest path

Which Should You Take First?

This is not a "which comes first" question — it is a career path decision. If you want to work at a broker-dealer selling securities on commission (the traditional Wall Street path), take the SIE first, then the Series 7 with firm sponsorship. If you want to work at a fee-only RIA firm providing fiduciary investment advice, skip the SIE entirely and take the Series 65. The Series 65 requires NO SIE, NO firm sponsorship, and NO prior licenses. For career changers coming from outside financial services, the Series 65 is almost always the better choice because: (1) you can take it immediately without finding a sponsoring firm, (2) it qualifies you for fee-only advisory work, and (3) RIA firms actively recruit career changers with diverse professional backgrounds (CPAs, attorneys, engineers, educators). The only reason to start with the SIE is if you specifically want to sell securities on commission at a FINRA-member broker-dealer.

At a Glance: SIE vs Series 65

Exam Cost

$100

SIE

$187

Series 65

Pass Rate

74% (FINRA, 2019)

SIE

Not listed

Series 65

Standalone Earning Power

None (corequisite only)

SIE

$105,070 BLS median (personal financial advisors)

Series 65

SIE

People committed to the broker-dealer path who want to sell securities on commission — the SIE is step one toward the Series 7 and the traditional Wall Street career track

Series 65

Career changers, CFP candidates, and anyone who wants to provide fee-only investment advice at an RIA without ever entering the FINRA exam system

Start preparing today:

SIE Prep Series 65 Prep

Key Facts: SIE vs Series 65

1
The Series 65 does NOT require the SIE exam, firm sponsorship, or any prior license — anyone can register and take it, making it the fastest path to a financial advisory license for career changers.
2
The SIE and Series 65 represent two completely different career paths: the SIE feeds into the FINRA broker-dealer system (commissions), while the Series 65 feeds into the NASAA/RIA system (fee-based fiduciary advice).
3
Neither FINRA nor NASAA lists a Series 65 pass rate on its exam pages; FINRA statistics through August 31, 2019 showed a 74% first-attempt SIE pass rate.
4
Investment Adviser Representatives (Series 65 holders) fall under personal financial advisors, whose May 2025 median was $105,070 (BLS, SOC 13-2052).
5
SEC-registered investment advisers reported a record $176.8 trillion in assets under management for 2025 (IAA 2026 Investment Adviser Industry Snapshot).
6
The Series 65 exam is developed by NASAA (and administered for it by FINRA) and costs $187, while the SIE is a FINRA exam that costs $100 — their content is set by separate regulatory organizations.
7
Series 65 holders operate under a fiduciary standard, legally required to act in the client's best interest, whereas the broker-dealer path (SIE→Series 7) operates under Regulation Best Interest for retail recommendations.
8
BLS projects 1% growth from 2025 to 2035 for both personal financial advisors (Series 65 path) and securities sales agents (SIE and Series 7 path), slower than the 3% average.
9
BLS expects about 17,100 openings a year for personal financial advisors from 2025 to 2035, mostly to replace advisors who retire or change occupations.
10
The total cost to become a fully licensed IAR through the Series 65 path ranges from $362 to $837 (exam fee + prep course + state registration), significantly less than the $842-$1,272 required for the full SIE + Series 7 + state exam broker-dealer path.

Why This Comparison Matters

Fiduciary Standard

Series 65 = Fiduciary Duty

Series 65 holders operate under a fiduciary standard, legally required to act in the client's best interest — not just recommend "suitable" investments like broker-dealer reps.

$176.8 Trillion

SEC-Registered Adviser AUM

SEC-registered investment advisers reported $176.8 trillion in assets under management for 2025, up from $144.6 trillion in 2024 (IAA 2026 Investment Adviser Industry Snapshot).

The SIE vs Series 65 comparison is not about which exam is harder or cheaper — it is about choosing between two fundamentally different business models in financial services. The SIE is the gateway to FINRA's broker-dealer ecosystem, where registered representatives earn commissions by executing trades and selling products. The Series 65 is the gateway to the RIA (Registered Investment Adviser) ecosystem, where investment adviser representatives earn fees by managing assets and providing fiduciary advice. These are not two steps on the same ladder — they are two different ladders entirely.

This distinction matters enormously because the financial services industry is in the midst of a structural shift from commissions to fees. SEC-registered investment advisers reported a record $176.8 trillion in assets under management for 2025 (IAA 2026 Investment Adviser Industry Snapshot). The Series 65 lets you enter the advisory side of the industry without ever touching the FINRA exam system.

The most underappreciated advantage of the Series 65 is its accessibility for career changers. Unlike the Series 7 — which requires both the SIE and firm sponsorship via Form U4 — the Series 65 has zero prerequisites. No SIE. No sponsoring firm. No prior licenses. You open an enrollment window through FINRA (which administers the exam for NASAA), pay $187, pass the exam, and you are qualified to work as an IAR at any RIA firm in the country (subject to state registration). This makes the Series 65 the single fastest path from "no financial licenses" to "licensed to give investment advice."

What Each Exam Covers

SIE Exam Topics

Knowledge of Capital Markets

16%

Understanding Products and Their Risks

44%

Understanding Trading, Customer Accounts, and Prohibited Activities

31%

Overview of Regulatory Framework

Pass Rate: 74% first attempt, 82% overall (FINRA statistics through Aug. 31, 2019)

Series 65 Exam Topics

Economic Factors and Business Information

15%

Investment Vehicle Characteristics

25%

Client Investment Recommendations and Strategies

30%

Laws, Regulations, and Guidelines (Including Prohibition on Unethical Business Practices)

30%

Pass Rate: No official pass rate is listed on FINRA's or NASAA's exam pages

Salary & Income Comparison

Personal Financial Advisors (BLS)

$105,070

Median Annual Salary

Range: $50,190 - $357,020+

BLS OOH, May 2025 (SOC 13-2052)

The SIE alone has no earning power — it is a corequisite, not a license. The real comparison is between the broker-dealer path (SIE → Series 7) and the RIA advisory path (Series 65), and BLS does not report pay by license. Securities sales agents, the occupation for most Series 7 representatives, earned a median of $78,660 in May 2025 (BLS, SOC 41-3031). Personal financial advisors, the occupation for most Series 65 investment adviser representatives, earned a median of $105,070 (BLS, SOC 13-2052).

The key difference lies in the revenue model. Broker-dealer reps earn commissions on transactions — income is episodic and requires constant new sales activity. RIA advisors earn asset-based fees — income recurs and grows as client portfolios grow.

Total Cost to Get Licensed

Expense	SIE	Series 65
Pre-Licensing Education	$0 (no pre-licensing course required, though $150-$400 for optional prep course recommended)	$150 - $400 (prep course: Kaplan $299-$349, Achievable $149, ExamFX $199-$349, STC $249-$349)
Exam Fee	$100 (FINRA)	$187 (NASAA/Prometric)
License Fee	N/A (SIE is not a license — additional exams required)	$25 - $200 (state IAR registration fee varies by state; e.g., California $50, New York $200, Texas $25)
Background Check	N/A (no Form U4 filing for SIE alone)	$0 - $50 (some states require a background check for IAR registration; many do not)
Total Investment	$100 - $500 (exam fee + optional prep course). Note: the SIE alone does not allow you to earn money in financial services.	$362 - $837 (exam fee + prep course + state registration). This is the complete cost to become a licensed Investment Adviser Representative — no SIE or additional FINRA exams required.

A Day in the Life

SIE Professional

A recent college graduate who passed the SIE last month arrives at a campus career fair. He stops at the Edward Jones and Ameriprise booths, mentioning that he already holds the SIE credential. Recruiters are visibly impressed — most college applicants have not taken the initiative to pass any FINRA exam on their own. Over lunch, he reviews options pricing formulas from his Series 7 study guide, knowing he will need to master that material once he secures firm sponsorship. In the afternoon, he has a video interview with a regional broker-dealer. The hiring manager explains the 120-day training window: "We sponsor you for the Series 7 and Series 66 and cover all exam fees, with a base salary during training." By the end of the week, he receives an offer. His SIE credential made the difference — it showed he was already invested in the career before the firm invested in him.

Series 65 Professional

A former CPA who passed the Series 65 three months ago starts her day at a fee-only RIA firm managing $450M in client assets. At 8:30 AM, she reviews overnight market movements and checks her calendar — two client reviews and a new prospect meeting today. At 9:30, she meets with a retired couple whose $1.2M portfolio is up 12% this year; she recommends rebalancing into more fixed income as they approach their distribution phase, walking them through the tax implications of each trade. There are no commissions to consider — every recommendation is made solely in the client's interest under the fiduciary standard. After lunch, she conducts a comprehensive financial plan presentation for a 45-year-old surgeon, covering retirement projections, tax optimization strategies, college funding for three children, and estate planning. The surgeon signs an advisory agreement for ongoing portfolio management at 0.80% of AUM. At 3:00 PM, she joins a team meeting where the firm's chief investment officer reviews the quarterly model portfolio changes. She ends the day feeling confident — no sales quotas, no product pushing, just advice that genuinely helps clients build wealth.

Career Paths & Progression

The SIE path leads to the broker-dealer world, which is the traditional Wall Street career track. After passing the SIE, you need a FINRA-member firm to sponsor you for the Series 7, which authorizes you to sell all types of securities. Most broker-dealer careers follow one of three routes: (1) wirehouse advisor at Morgan Stanley, Merrill Lynch, UBS, or Wells Fargo, earning grid-based compensation; (2) independent broker-dealer rep at LPL, Raymond James, or Cetera, keeping a larger share of revenue; or (3) institutional sales/trading, where you sell securities to hedge funds, pension funds, and other institutional buyers.

The Series 65 path leads to the RIA (Registered Investment Adviser) world. Series 65 holders work as IARs at fee-only or fee-based advisory firms, providing fiduciary investment advice and financial planning. Career tracks include: (1) fee-only financial planner at firms like Buckingham Strategic Wealth, Plancorp, or local independent RIAs, earning flat fees or AUM-based fees with zero conflicts of interest; (2) robo-advisor/hybrid advisor at firms like Vanguard Personal Advisor Services, Betterment, or Wealthfront, combining technology with human advice; or (3) RIA firm owner, starting your own advisory practice — the Series 65 is often the qualifying exam needed to register an RIA with your state. The key advantage of the RIA path is recurring revenue: AUM fees compound as markets grow and clients add assets, creating a business with enterprise value.

Start preparing today:

SIE Prep Series 65 Prep

Should You Get Both the SIE (→Series 7) AND the Series 65?

Benefits

+
Holding both the Series 7 and Series 65 (or the combined Series 66, which requires the Series 7) allows you to work at dual-registered firms that offer both brokerage and advisory services
+
The Series 7 + Series 66 combination (which includes Series 65 equivalent content) is the gold standard for full-service financial advisors who want maximum career flexibility
+
Some advisory services — like selling variable annuities or executing trades for advisory clients — require both a brokerage license (Series 7) and advisory registration (Series 65/66)
+
Dual licensing maximizes your employability: you can work at broker-dealers, RIA firms, AND dual-registered/hybrid firms
+
If you start at a broker-dealer and later want to move to a fee-only RIA, having the Series 65 already eliminates a licensing hurdle

Considerations

!
If you only want to provide fee-only advice at an RIA firm, the Series 65 alone is sufficient — there is no need to take the SIE or Series 7, saving you $495+ in exam fees and 120-180 hours of additional study time
!
The Series 7 requires firm sponsorship, so you cannot independently pursue it like the Series 65 — you must be employed by a FINRA-member broker-dealer
!
Many fee-only firms specifically do NOT want advisors with brokerage licenses because it creates potential conflicts of interest
!
If you are a career changer with limited time, the Series 65 alone is one exam, vs three for the SIE + Series 7 + Series 66 combination

The Verdict:

For most career changers entering financial services in 2026, the Series 65 alone is the fastest and most practical path. It requires no prerequisites and no firm sponsorship, and it qualifies you for fee-based advisory work. However, if you want maximum long-term flexibility — or if you plan to work at a wirehouse or full-service broker-dealer — the full SIE → Series 7 → Series 66 path gives you the broadest possible authority. The key question is: do you want to sell securities on commission (Series 7 path), provide fee-only advice (Series 65 path), or do both (Series 7 + Series 66)? Answer that question first, and the exam choice becomes obvious.

Job Outlook & Industry Trends

N/A (corequisite exam — see Series 7 for broker-dealer job outlook)

SIE Job Growth (2024-2034)

1% for personal financial advisors (2025-2035, BLS SOC 13-2052)

Series 65 Job Growth (2024-2034)

BLS projects 1% growth for personal financial advisors from 2025 to 2035, slower than the 3% average for all occupations, with about 17,100 openings a year, mostly to replace advisors who retire or change occupations. BLS expects demand from retiring baby boomers and younger clients with growing incomes, partly offset by AI-based advice tools. For career changers, the Series 65 is a low-barrier entry: no SIE or firm sponsorship is required.

Study Strategy & Tips

1Step 1

Career Path Decision

Decide between broker-dealer (SIE→S7) and RIA advisory (S65) career paths

Research the difference between broker-dealer and RIA business models — commissions vs. fees, suitability vs. fiduciary
Identify target employers: broker-dealers (Morgan Stanley, LPL) vs. RIA firms (Vanguard PAS, Buckingham, local fee-only shops)
Talk to professionals in both paths — LinkedIn informational interviews are invaluable
If choosing the RIA/fee-only path, proceed directly to Series 65 preparation and skip the SIE entirely

2Step 2

Series 65 Core Study (if choosing RIA path)

Master the four content areas of the Series 65

Complete a Series 65 prep course (Kaplan, Achievable, ExamFX, or STC)
Study Investment Vehicle Characteristics (25%) and Client Recommendations (30%) — this is 55% of the exam and requires solid investment knowledge
Study Laws, Regulations, and Ethics (30%) — memorize the Investment Advisers Act of 1940, state registration rules, Form ADV requirements, and prohibited practices
Review Economic Factors (15%) — GDP, CPI, yield curves, monetary/fiscal policy, business cycle indicators

3Step 3

Series 65 Practice & Pass

Full-length practice exams and weak-area remediation

Take 4-5 full-length timed practice exams (130 questions, 3 hours)
Target 78%+ on practice exams before scheduling the real exam (passing requires 92 of 130 correct, but build a buffer for NASAA's tricky question style)
Focus extra study on your weakest section — most candidates struggle with the regulatory content in Section 4
Schedule and pass the Series 65 exam at a Prometric testing center

4Step 2 (alternative track)

SIE Preparation (if choosing broker-dealer path)

Foundational securities knowledge for the FINRA path

Complete an SIE prep course — focus on Products and Their Risks (44% of exam)
Study Trading, Accounts, and Prohibited Activities (31%) — order types, account types, insider trading
Review Capital Markets (16%) and Regulatory Framework (9%)
Take 3+ full-length practice exams scoring 80%+ before scheduling

Total Duration: Self-paced (FINRA and NASAA publish no study-time guidance)

SIE Study Tips

1
Focus 44% of your study time on Products and Their Risks — this is nearly half the exam. Know the characteristics, risks, and suitability of equities, debt securities, packaged products (mutual funds, ETFs), options basics, and alternative investments.
2
Understand the difference between primary and secondary markets, market maker roles, and how securities are issued. Capital Markets questions are straightforward if you understand the flow of money from issuer to investor.
3
Memorize the regulatory bodies and their jurisdictions: FINRA regulates broker-dealers, SEC oversees the markets, MSRB governs municipal securities, and state regulators enforce blue sky laws. This is 9% of the exam but it is easy points if you study it.
4
Take at least 3 full-length practice exams under timed conditions. The SIE tests breadth over depth — you need rapid concept recognition across a wide range of topics rather than deep calculation skills.
5
Do NOT over-study. The SIE is designed as an entry-level exam. If you are spending time on options strategies, bond duration calculations, or complex suitability scenarios, you have gone too deep — save that for the Series 7.

Series 65 Study Tips

1
The Series 65 is 60% investment knowledge (Sections 2 and 3) and 40% regulatory/ethical content (Sections 1 and 4). Unlike the Series 7 which is calculation-heavy, the Series 65 emphasizes understanding of fiduciary duty, the Investment Advisers Act of 1940, and state registration requirements. Study both halves equally.
2
Master the legal and regulatory content — 30% of the exam covers laws, regulations, and ethical practices. Know the difference between federal-covered and state-registered advisors, registration requirements, brochure delivery rules (Form ADV Parts 2A and 2B), and prohibited practices like churning, front-running, and commingling client funds.
3
Understand Modern Portfolio Theory, asset allocation, and portfolio management concepts thoroughly. The exam tests your ability to recommend suitable investment strategies based on client objectives, risk tolerance, time horizon, and liquidity needs — all under the fiduciary standard.
4
Learn the economic indicators and their implications: GDP, CPI, unemployment rate, yield curves, monetary and fiscal policy. Section 1 (15%) is the most conceptual part of the exam and rewards candidates with a solid economics foundation.
5
Take at least 4-5 full-length practice exams under timed conditions. The Series 65 has 130 scored questions in 3 hours, which gives you about 1 minute 23 seconds per question — time management is critical. Many candidates report the exam feels more difficult than practice tests because NASAA questions are notoriously tricky with subtle answer distinctions.

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Frequently Asked Questions

QDo I need the SIE to take the Series 65?

No. The Series 65 is a NASAA (North American Securities Administrators Association) exam that FINRA administers on NASAA's behalf, and it does not require any FINRA exam. You do not need the SIE, firm sponsorship, or any prior license to take the Series 65. You simply request an exam enrollment window through FINRA, pay the $187 exam fee, and schedule your test at a Prometric center. This is one of the biggest advantages of the Series 65 for career changers — you can go from zero licenses to fully qualified Investment Adviser Representative.

QWhat is the difference between the broker-dealer path and the RIA path?

The broker-dealer path (SIE → Series 7) allows you to sell securities on commission as a registered representative at a FINRA-member firm. You earn money each time a client buys or sells a security, and you operate under a suitability standard — meaning your recommendations must be "suitable" but not necessarily in the client's best interest. The RIA path (Series 65) allows you to provide investment advice for fees as an Investment Adviser Representative at a Registered Investment Adviser firm. You earn recurring AUM-based fees, hourly fees, or flat planning fees, and you operate under a fiduciary standard — meaning you are legally required to act in the client's best interest at all times. The industry trend is decisively moving toward the fee-based RIA model.

QWhich exam should a career changer take — the SIE or Series 65?

For most career changers, the Series 65 is the better choice. It requires no prerequisites (no SIE, no firm sponsorship), is a single exam, and immediately qualifies you for roles at RIA firms. The SIE, by contrast, is merely a corequisite that does not authorize you to do anything on its own; you would still need firm sponsorship and the Series 7 (another 80-120 hours of study) to actually work in the industry. RIA firms also actively recruit career changers with diverse backgrounds — CPAs, attorneys, educators, engineers — because advisory work values life experience and relationship skills, not just financial knowledge.

QHow much do Series 65 holders earn compared to Series 7 holders?

BLS does not report pay by license. Securities sales agents, the occupation for most Series 7 representatives, had a May 2025 median of $78,660, and personal financial advisors, the occupation for most Series 65 investment adviser representatives, had a median of $105,070 (BLS). Series 7 holders earn commissions on each transaction, creating episodic income that requires constant sales activity. Series 65 holders at RIA firms earn asset-based fees that recur as long as clients stay.

QIs the Series 65 harder than the SIE?

Yes, the Series 65 is meaningfully more difficult. It has more questions (130 scored vs 75 scored), a longer testing time (3 hours vs 1 hour 45 minutes), and a raw passing cut (92 of 130 correct) that is not directly comparable with the SIE's scaled 70. The content is also more demanding: the Series 65 requires understanding of Modern Portfolio Theory, portfolio management, the Investment Advisers Act of 1940, state registration requirements, and complex suitability analysis under the fiduciary standard. NASAA is known for writing tricky questions with subtle answer distinctions. However, the Series 65 is considered easier than the Series 7, which covers options calculations, bond pricing, and margin requirements in much greater depth.

QCan I work at a fee-only RIA firm with just the Series 65?

Yes — the Series 65 is the only exam required to work as an Investment Adviser Representative (IAR) at a fee-only RIA firm. After passing, you register as an IAR in your state (registration fees range from $25-$200 depending on the state), and you are fully authorized to provide personalized investment advice, manage client portfolios, create financial plans, and charge fees for your services. You do not need the SIE, Series 7, or any other FINRA exam. Many of the most respected fee-only advisory firms in the country — including firms managing billions in client assets — employ advisors whose only securities license is the Series 65. If the firm also has a broker-dealer affiliation (a dual-registered or hybrid firm), you may eventually need the Series 7 to execute certain transactions, but pure fee-only RIA firms require only the Series 65.

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