Series 65 Cheat Sheet
The thresholds, periods, and exemptions worth memorizing cold. Hit ⌘P to print on one page.
Series 65 Cheat Sheet
LATTICE · series65.alchemaize.ai · for personal study use
Registration tiers — AUM
| < $25M AUM | STATE only (small adviser) |
| $25M – $100M | STATE (mid-size). Exceptions: NY → SEC; no home-state exam → SEC |
| $100M – $110M | CHOICE — state or SEC |
| ≥ $110M | SEC required (large adviser) |
| AUM falls below $90M | Must withdraw from SEC, register with state |
Dollar thresholds
| $1M | Accredited investor — net worth (excl. primary residence) |
| $200K / $300K | Accredited investor — income (single / joint), past 2 yrs |
| $1.1M | Qualified client — AUM with the adviser |
| $2.2M | Qualified client — net worth (excl. primary residence) |
| $5M | Qualified purchaser — individual investments |
| $25M+ | Qualified purchaser — other entities (investments, not net worth) |
| $25M | Mid-size IA threshold (lower bound) |
| $100M / $110M / $90M | SEC registration threshold / buffer(110 up / 90 down) |
| $200M | Pension consultant SEC threshold |
| $10,000 | CTR cash reporting trigger; first-home IRA exception ($10K lifetime) |
| $50,000 | Max 401(k)-style loan (or 50% of vested balance, lesser of) |
| $19,000 | Annual gift tax exclusion per recipient (2025) |
| $13.99M | Lifetime gift/estate tax exemption per person (2025) |
| $3,000 | Cap loss offset against ordinary income per year |
| $7,000 / +$1,000 | IRA contribution / 50+ catch-up (2025) |
| $23,500 / +$7,500 | 401(k) elective / 50+ catch-up (60–63: $11,250 super) |
| $70,000 | SEP / Solo 401(k) overall annual limit (2025) |
| $500/year | Impersonal advice de minimis — no IA reg needed |
| $350 / $150 | Pay-to-play de minimis political contribution (can vote / cannot) |
Time periods
| 24 hours | Reg FD — unintentional disclosure remedy window |
| 2 business days | Form 4 — insider transaction reporting |
| 3 business days | Inadvertent custody — return check to avoid custody |
| 10 business days | Discretion — must be in writing after first oral use |
| 30 days | Registration effective; Form U5 (BD departure); Form BD update |
| 60 days | Qualified dividend holding period (within 121-day window) |
| 90 days | Form ADV annual updating amendment after fiscal year-end |
| 120 days | Material change communication to clients (calendar year-end + 120) |
| 180 minutes | Series 65 exam — total time |
| 5 years | Books and records retention; criminal statute of limitations |
| 3 / 2 years | Civil SOL under USA: 3 from sale / 2 from discovery |
| 10 years | Disqualifying misdemeanor lookback |
Percentages
| 72% | Series 65 passing score (94 of 130) |
| 5% | Markup/markdown guideline (FINRA 5% policy) |
| 25% | SEP IRA — max % of compensation (capped at $70K) |
| 10% | Early withdrawal penalty (under 59½) on most retirement accounts |
| 3.8% | Net Investment Income Tax (MAGI > $200K single / $250K joint) |
| 7.5% | Medical expenses threshold (% of AGI) for 10% penalty exception |
| 100% | Roth conversion taxable (full amount) |
Key forms
| Form ADV Part 1 | Adviser identity, AUM, ownership, disciplinary history |
| Form ADV Part 2A | Brochure — plain English narrative (firm) |
| Form ADV Part 2B | Brochure supplement (specific IAR's background) |
| Form ADV-W | Withdrawal from registration |
| Form U4 | IAR initial registration (Uniform Application) |
| Form U5 | IAR termination notice (filed within 30 days) |
| Form BD / BDW | Broker-dealer registration / withdrawal |
| Form D | Reg D private placement notice (within 15 days of first sale) |
USA vs IAA40 — what's where
| State (USA §301) | Securities registration in each state of offer/sale |
| State (USA §401) | Definitions: 'broker-dealer', 'agent', 'IA', 'IAR' |
| Federal (IAA40 §202) | Definition of 'investment adviser' |
| Federal (IAA40 §203A) | SEC vs state registration split (Dodd-Frank) |
| Federal (IAA40 §205) | Advisory contracts: assignment, performance fees, partnership notice |
| Federal (Rule 204-3) | Brochure delivery: before or at contract |
| Federal (Rule 206(4)-2) | Custody — qualified custodian, surprise exam, notices |
| Federal (Rule 206(4)-5) | Pay-to-play — 2-year time-out; $350/$150 de minimis |
Safe harbors & exclusions
| LATE — Lawyers, Accountants, Teachers, Engineers | USA §202(a)(11) IA exclusion when advice is incidental |
| BANC — Banks, Agents (BD), Newspapers, Credentialed pubs | IA exclusions / not BD |
| Inadvertent custody return ≤ 3 days | Returning misaddressed check within 3 business days = no custody |
| Direct fee deduction + custodian sends statements | Custody exists but full surprise exam exempt |