FINRA Series 7 vs. Series 82 vs. Series 79: Which License Is Right for You?
Updated: Aug 17
For professionals working in mergers and acquisitions, private placements and capital raising, FINRA licensing is critically important — and frequently misunderstood.
We regularly hear questions like:
Which FINRA exam do I actually need?
Do I need the Series 7, Series 82 or Series 79?
Does a Series 7 cover investment banking?
Can a Series 82 be used for M&A?
If I have a Series 79, can I solicit investors?
What is the SIE?
What about state registration and the Series 63?
When do I need broker-dealer sponsorship?
These distinctions matter because FINRA does not simply require someone to be “licensed.” The registration category needs to correspond to the functions and responsibilities the individual actually performs.
FINRA Rule 1210 requires individuals engaged in a member firm’s investment banking or securities business to register in each category appropriate to their functions and responsibilities, while FINRA Rule 1220 establishes the specific registration categories.
For independent investment bankers, M&A advisors and private-placement professionals, the three representative-level registrations we encounter most frequently are:
They overlap in some areas, but they are not interchangeable. Understanding the differences is essential both for remaining appropriately registered and for understanding what business opportunities your current registrations may — or may not — allow you to pursue.
Why FINRA Licensing Matters for M&A and Capital Raising
Professionals who engage in securities transactions, raise capital, advise on securities-related M&A transactions or receive transaction-based compensation in connection with securities activity should carefully evaluate whether broker-dealer registration is required.
There are exemptions and specific regulatory frameworks that may apply to certain M&A brokers and other professionals, so the analysis is not as simple as saying that every person involved in every M&A transaction must be FINRA registered. But when an individual conducts securities or investment-banking business through a FINRA member broker-dealer, FINRA’s registration rules determine which qualification categories apply to that person’s actual functions.
FINRA Rule 1220(b) is the key starting point.
It defines the various representative registration categories and, importantly, distinguishes between the General Securities Representative, Investment Banking Representative and Private Securities Offerings Representative categories.
The SIE Exam: The Starting Point for New Entrants
Since October 2018, FINRA has used the Securities Industry Essentials (SIE) exam as the introductory examination for prospective securities-industry professionals.
The SIE covers fundamental concepts such as:
Securities products and their risks
Securities markets
Regulatory agencies
Industry structure
Prohibited practices
Unlike the Series 7, Series 79 and Series 82 representative-level exams, you do not need broker-dealer sponsorship to take the SIE. Anyone age 18 or older can take it, and a passing result is generally valid for four years.
The current SIE consists of:
75 questions
1 hour and 45 minutes
$100 exam fee
Passing the SIE alone does not make someone FINRA registered. To obtain Series 7, Series 79 or Series 82 registration, the individual must also pass the corresponding representative-level qualification exam and become appropriately registered through a member firm.
Because the SIE does not require sponsorship, we often recommend prospective representatives complete it independently before beginning the broker-dealer registration process.
Series 79: Investment Banking Representative
For professionals engaged in M&A and investment banking, the Series 79 is particularly important because FINRA Rule 1220(b)(5) specifically defines the activities requiring registration as an Investment Banking Representative.
FINRA requires the Series 79 Investment Banking Representative registration when a representative’s activities involve the critical functions of an investment banking representative, such as advising on or facilitating debt or equity securities offerings through a private placement or a public offering and mergers and acquisitions. This includes origination, underwriting, marketing, structuring, syndication and pricing; or advising on or facilitating mergers and acquisitions, tender offers, financial restructurings, asset sales, divestitures, corporate reorganizations or other business combination transactions, including rendering fairness, solvency or similar opinions.
FINRA expressly places advising on or facilitating mergers and acquisitions within the Series 79 Investment Banking Representative category.
The current Series 79 exam consists of:
75 questions
2 hours and 30 minutes
$395 exam fee
The SIE is a core pre-requisite. For those studying through Kaplan, you can ask us for our Britehorn discount code.
Series 82: Private Securities Offerings Representative
The Series 82 is FINRA’s limited registration for Private Securities Offerings Representatives. Under FINRA Rule 1220(b)(9), the registration applies to representatives whose activities are limited to effecting sales as part of a primary offering of securities not involving a public offering.
That’s an important sentence because both private and primary matter. Consider a private company raising $20 million in growth capital by issuing new preferred shares. The company issues new securities. Investors purchase those securities. The $20 million goes to the company. That’s a primary private offering — exactly the type of securities-sales activity for which Series 82 was designed.
The Series 82 consists of:
50 questions
1 hour and 30 minutes
$100 exam fee
The SIE is a core pre-requisite.
The Series 82 is substantially narrower than Series 7, but for professionals whose securities-sales activities are confined to private primary capital raises, that narrower scope can make it an efficient qualification.
Series 7: General Securities Representative
The Series 7 is FINRA’s broad General Securities Representative qualification. It is also one of FINRA’s oldest active representative exams, dating to 1974. Unlike Series 82, it isn’t confined to private primary offerings. FINRA states that a Series 7 representative is qualified for the solicitation, purchase and/or sale of securities products including:
Corporate securities
Public offerings and private placements
Municipal securities sales
Investment-company products
Options
Direct participation programs
Venture capital
Hedge funds
Government securities
Various other securities products
For professionals expecting to conduct a broad range of securities business, the Series 7 provides considerably greater flexibility than Series 82 — including the ability to engage with secondary offerings and public securities.
The current Series 7 consists of:
125 questions
3 hours and 45 minutes
$395 exam fee
The SIE is a core pre-requisite. For those using Kaplan as a study tool, you can ask us for our Britehorn discount code.
What About PIPE Financings?
PIPE stands for Private Investment in Public Equity. A common misconception is that a PIPE automatically requires Series 7 because the issuer is publicly traded.
That’s too simplistic. A PIPE generally involves a public company privately placing securities with investors. For Series 82 purposes, the critical distinction isn’t merely whether the issuer is public or private. Rule 1220(b)(9) focuses on whether the transaction is a primary offering not involving a public offering. And FINRA’s own Series 82 Content Outline specifically includes a Private Investment in Public Equity (PIPE) among the types of securities offerings relevant to Series 82 representatives. That means a qualifying primary PIPE can fall within the Series 82 private-offering universe, even though the issuer itself is publicly traded. The key distinction is: Public company ≠ necessarily public offering.
At the same time, if someone performs investment-banking functions in connection with the PIPE — structuring, pricing, advising the issuer or other Series 79 functions — Series 79 requirements must be analyzed separately.
The Series 7 Does Include Series 82 Private-Placement Activity
This is another important point. Rule 1220(b)(2) establishes the General Securities Representative category and provides that representatives whose activities are limited solely to certain specialized functions — including Private Securities Offerings Representative functions — can obtain those limited registrations in lieu of Series 7. The reverse implication also stands: The Series 7 already provides the broader securities-sales authority, and you do not need Series 82 in addition to Series 7 merely to solicit and sell qualifying private placements.
But the Series 7 has one critical limitation for investment bankers.
The Series 7 Does Not Replace the Series 79
This is where FINRA Rule 1220(b)(2) becomes particularly important.
Rule 1220(b)(2)(A)(i) says that when a General Securities Representative’s activities include certain specialized functions — including the functions of an Investment Banking Representative — the individual must appropriately register in those specialized categories.
FINRA’s Series 79 FAQ makes the distinction even clearer. A Series 7 representative can actively sell and market securities, but if that representative also performs Series 79-type investment-banking functions — for example, preparing a marketing plan, advising a sales team on the marketing plan or developing information for offering marketing materials — FINRA says the individual must also register as an Investment Banking Representative.
This is where some long-time investment bankers and obtained the Series 7 General Securities Representative registration before the Series 79 came out may have been grandfathered into Series 79 credit, but per FINRA Regulatory Notice 09-41, this credit must have been applied for between November 2009 and May 2010. So a veteran investment banker may legitimately hold Investment Banking Representative registration without ever having taken the Series 79, because the individual obtained the registration through the 2009–2010 opt-in process. But simply having held a Series 7 before 2009 does not, by itself, permanently grandfather someone into Series 79 activity. This distinction was tested in an SEC proceeding involving an experienced Series 7 representative who had not taken advantage of the opt-in period and later sought a waiver from the Series 79 examination. The SEC upheld FINRA’s denial of the waiver.
Three Registrations, Three Different Functions
It is more useful to think of Series 7, Series 79 and Series 82 as registrations for different functions rather than simply three progressively broader versions of the same license.
Series 79 — Investment Banking
Think: M&A + investment-banking activity involving securities offerings.
This includes advising on or facilitating M&A transactions and performing the investment-banking functions FINRA identifies in connection with private and public securities offerings.
Series 82 — Private Securities Offerings
Think: Private primary offerings.
The Series 82 permits solicitation and sale of private-placement securities as part of primary offerings and can also cover certain private-offering structuring activities.
That universe can include qualifying PIPE transactions even though the issuer itself is publicly traded.
Series 7 — General Securities
Think: Broad securities-sales authority.
The Series 7 extends beyond the Series 82’s private-primary-offering limitation and provides substantially greater flexibility for representatives whose businesses involve private and public securities or primary and secondary securities transactions. But the Series 7 does not eliminate a Series 79 requirement when the representative performs activities FINRA classifies as investment banking.
What This Means in Real-World Deals
A few examples make the distinction much easier to understand.
Scenario A: M&A Advisory
You’re advising a founder on the sale of her company. You provide valuation analysis, prepare transaction materials, develop the buyer universe, negotiate transaction terms and advise throughout the sale process.
The Series 79 is the specialized investment-banking registration applicable to that M&A activity.
Scenario B: Private Growth-Capital Raise
A private company wants to raise $30 million by issuing new preferred shares.
You advise the company on structure, valuation, financing strategy and the offering.
The Series 82 or Series 7 can provide the additional securities-sales registration appropriate for those activities.
Scenario C: Private Secondary Transaction
An early investor wants to sell an existing block of private-company shares to another investor. No new securities are being issued and the issuer isn’t receiving the proceeds.
The Series 82 is specifically limited to private placements conducted as part of a primary offering. The broader securities authority associated with Series 7 becomes relevant to secondary securities transactions that fall outside the Series 82 category.
Scenario D: PIPE Financing
A publicly traded company raises capital by privately issuing securities to institutional or accredited investors.
The fact that the issuer is publicly traded does not automatically make the transaction a public offering. A qualifying primary PIPE can fall within the Series 82 private-offering universe. If the representative’s role also encompasses Series 79 investment-banking functions, however, the appropriate Investment Banking Representative registration must be considered separately.
Scenario E: Registered Public Offering
A company conducts a registered public securities offering and you actively solicit investors and effect sales.
The Series 82 isn’t sufficient because its authority is limited to private offerings.
The Series 7 provides the broader securities-sales registration, while the Series 79 applies to representatives performing the investment-banking functions FINRA identifies in connection with the offering.
When Is Broker-Dealer Sponsorship Required?
FINRA representative-level qualification exams such as Series 7, Series 79 and Series 82 generally require association with and sponsorship by a FINRA member firm (such as Britehorn Securities). The SIE does not.
If you need a Series 7, Series 79 or Series 82 for the securities or investment-banking business you plan to conduct, you therefore generally need to become associated with an appropriate broker-dealer before taking the top-off exam.
State Licensing and the Series 63
FINRA registration is only part of the licensing analysis. Registered representatives also need to satisfy state-level agent registration requirements.
The Series 63 — Uniform Securities Agent State Law Examination is administered through NASAA and tests state securities-law concepts. Unlike real estate licenses, this one exam allows you to register in any and all U.S. states and territories — which is a big reason many real estate professionals choose to become FINRA-registered if they do more than pure asset sales.
Unlike Series 7, Series 79 and Series 82, the Series 63 does not require broker-dealer sponsorship to sit for the exam. Together with the SIE, it can be taken before you decide on a broker-dealer affiliation.
What If You Have a Series 66?
The Series 66 combines state-law concepts applicable to both broker-dealer agents and investment-adviser representatives. NASAA explains that when combined with a valid SIE and Series 7, Series 66 qualifies an individual as though the person had passed both Series 63 and Series 65. We can therefore request Series 63 exam credit if you register with us while having a valid Series 66 license (but these expire every 2 years).
License Expiration and the MQP
FINRA qualification examinations such as Series 7, Series 79 and Series 82 generally maintain validity through the corresponding registration. After a registration terminates, the qualification generally remains valid for 2 years.
The SIE generally remains valid for 4 years.
FINRA’s new Maintaining Qualifications Program (MQP) provides eligible former registered persons another option. Eligible individuals can maintain certain terminated FINRA qualifications for up to 5 years by participating in the program, completing required annual continuing education and remaining eligible.
The current annual MQP participation fee is $100, regardless of the number of eligible qualifications maintained. Importantly, participation in MQP does not allow someone to conduct securities business while unaffiliated with a broker-dealer. It preserves qualification status so an eligible person can potentially reregister without retaking the qualification examination.
You can read more on that in our article about the MQP Program.
What About Series 63 and NASAA EVEP?
State qualifications operate separately. The NASAA’s Exam Validity Extension Program (EVEP) provides a mechanism through which eligible individuals can extend the validity of their Series 63, 65 and applicable Series 66 exam credits for up to five years, subject to program requirements and adoption by the relevant jurisdiction.
Because state participation and individual circumstances vary, representatives should not assume FINRA MQP participation automatically preserves their state qualifications. You can read more on that in our article about the MQP Program.
Choosing the Right Licensing Path
There isn’t one FINRA license that is universally “best.” The appropriate registration depends on what you actually do.
If you’re advising on M&A transactions and performing investment-banking functions, the Series 79 is the specialized registration FINRA created for that work. If your securities business is limited to soliciting and selling securities in private primary offerings, the Series 82 may provide the securities-sales authority you need. If you want broader securities-sales authority across private and public markets and primary and secondary transactions, the Series 7 provides substantially greater flexibility and encompasses the private-placement sales activities otherwise permitted under Series 82.
For many independent investment bankers, therefore, the question isn’t simply:
“Which exam should I take?”
It is:
“Which combination of registrations matches the business I conduct today — and the business I want to conduct tomorrow?”
At Britehorn Securities, we take a consultative approach to registration. We work with our Registered Representatives to understand the M&A, capital-raising and securities activities they actually conduct, determine which registrations are appropriate for those functions and provide sponsorship for applicable FINRA qualification exams. Have questions about Series 7, Series 79, Series 82 or which registration structure may be appropriate for your investment-banking practice? Get in touch with us.
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