Last Modified: August 14, 2026
Table of Contents
The North American Securities Administrators Association — NASAA — is a voluntary association of sixty-seven state, provincial, and territorial securities regulators from the fifty United States, the District of Columbia, Puerto Rico, the United States Virgin Islands, and the provinces and territories of Canada and Mexico, founded in Kansas in 1919 as the oldest international organisation devoted to investor protection.
NASAA is not itself a regulatory body and has no independent enforcement authority. It is a coordinating and standard-setting association through which member state securities administrators collaborate, share enforcement intelligence, develop model legislation, and speak collectively on investor protection policy before Congress, the SEC, and other federal bodies.
For securities industry professionals, NASAA's most direct practical significance is the examination programme it develops — the Series 63, Series 65, and Series 66 state law qualification examinations, all administered by FINRA under a long-standing service agreement between the two organisations.
NASAA was founded in Kansas in 1919 — the same state that in 1911 had enacted the first blue sky law in United States history, a statute prompted by aggressive promoters who were said to be selling investors nothing more than a piece of the blue sky. Other states rapidly followed Kansas's lead, and by the time of the First World War nearly every state in the country had enacted its own securities registration and anti-fraud statute.
This proliferation of state law was tested before the United States Supreme Court in Hall v. Geiger-Jones Co. (1917), which upheld the constitutionality of state blue sky laws against a challenge that they impermissibly burdened interstate commerce.
The decision confirmed that state securities regulation was here to stay — and with dozens of states now administering their own registration and enforcement regimes, the individual commissioners and administrators charged with enforcing these laws recognised a shared need to compare practices, coordinate against fraud that crossed state lines, and speak with one voice on policy matters.
That recognition led directly to NASAA's founding in 1919, making it older than the Securities and Exchange Commission itself by some fifteen years.
The name North American Securities Administrators Association reflects the founding vision of coordination not only among United States state regulators but also among provincial securities administrators in Canada — whose securities regulatory framework similarly operates at the provincial rather than federal level, with no single national securities regulator equivalent to the SEC.
Mexican securities regulators subsequently joined as well, giving the association its present North American, cross-border scope and its sixty-seven-member roster.
NASAA is a membership-driven, not-for-profit association headquartered in Washington, D.C., governed by an elected President and a Board of Directors drawn from the membership, with officers typically serving one-year terms and standing for election at NASAA's annual meeting.
A professional staff, led by an Executive Director, supports the association's day-to-day operations, policy advocacy, and coordination work on behalf of the membership.
Much of NASAA's substantive work is carried out through standing committees and sections organised around the major functional areas of state securities regulation — including enforcement, corporation finance and capital formation, investment adviser regulation, broker-dealer regulation, and investor education.
These bodies draft model rules and policy statements, coordinate training for state examination and enforcement staff, and develop the association's positions on federal legislative and rulemaking proposals before they are adopted by the full membership.
NASAA's sixty-seven members are the state securities administrators — the officials or agencies responsible for administering state securities laws within each jurisdiction.
Each administrator holds broad regulatory authority under their state's securities laws including the power to register or deny registration to broker-dealers, agents, investment advisers, and investment adviser representatives, investigate potential violations, issue subpoenas, issue cease and desist orders, impose civil monetary penalties, revoke registrations, and refer criminal matters to the state attorney general for prosecution.
Because NASAA members are state regulators rather than federal regulators they are geographically closest to the investors they protect — giving them particular effectiveness in investigating locally concentrated fraud schemes and protecting elderly and vulnerable investors in their communities.
This local presence is frequently cited as state regulation's chief comparative advantage over a purely federal enforcement model, since state examiners and investigators are typically the first regulatory contact for a defrauded investor.
NASAA develops the content of three state law qualification examinations administered by FINRA.
Series 63 — Uniform Securities Agent State Law Examination. Required for registration as an agent of a broker-dealer in most states alongside the SIE and an applicable product examination such as the Series 7.
Sixty-five questions — sixty scored — seventy-five minutes — passing score seventy-two percent.
Series 65 — Uniform Investment Adviser Law Examination. The primary qualification for registration as an investment adviser representative under state law. One hundred and forty questions — one hundred and thirty scored — three hours — passing score seventy-two percent. Does not require firm sponsorship — any individual may sit independently.
Series 66 — Uniform Combined State Law Examination. Combines the Series 63 and the state law portion of the Series 65 into a single examination qualifying candidates as both securities agents and investment adviser representatives. One hundred questions — ninety-five scored — one hundred and fifty minutes — passing score seventy-three percent. Does not require firm sponsorship. Because the Series 66 assumes the product knowledge already tested on the Series 7, candidates typically sit it only after completing a product examination, whereas the Series 65 can be taken as a stand-alone qualification.
NASAA publishes the content outlines for all three examinations on its website — these are the authoritative guides for examination preparation, and NASAA periodically updates them to reflect changes in state and federal securities law, meaning candidates should always confirm they are studying against the current outline rather than an outdated version.
The foundational document of state securities regulation is the Uniform Securities Act — the model law originally developed by the Uniform Law Commission (then the National Conference of Commissioners on Uniform State Laws) and periodically revised over subsequent decades, most recently refined through NASAA's ongoing model rule and policy statement programme.
The Act was designed to give states a common statutory template covering securities registration, broker-dealer and investment adviser registration, and anti-fraud provisions, so that a patchwork of sixty-seven distinct blue sky regimes could nonetheless operate with a substantial degree of underlying consistency.
NASAA members may adopt NASAA model rules and policy statements as their own state regulations, creating greater uniformity across jurisdictions without requiring formal legislative action in each individual state legislature — a considerably faster and more flexible route to harmonisation than amending underlying statutes state by state.
Model rules address specific topics including dishonest and unethical business practices for broker-dealers and agents, dishonest and unethical practices for investment advisers and investment adviser representatives, requirements for broker-dealers conducting business on banking premises, recordkeeping requirements, and — reflecting NASAA's growing focus on demographic risk — model provisions specifically designed to protect senior and other vulnerable investors from financial exploitation.
Because each state administrator has jurisdiction only within its own state, coordinated action among multiple administrators is essential to address fraud schemes that span state lines — which describes the vast majority of significant investment fraud targeting retail investors, particularly schemes conducted online or by telephone that make no distinction between state borders.
NASAA coordinates multi-state enforcement actions through its enforcement committee — allowing multiple administrators to pool investigative resources, share evidence, and present a unified enforcement front that maximises regulatory impact.
This coordination is supported by shared registration and disciplinary infrastructure that NASAA members rely on jointly with FINRA, principally the Central Registration Depository (CRD) for broker-dealers and their agents and the Investment Adviser Registration Depository (IARD) for investment advisers and their representatives — systems that give every state administrator visibility into a firm's or individual's registration and disciplinary history in every other jurisdiction, not merely their own.
NASAA also publishes annual lists of the top investor threats identified by state regulators, drawn from a survey of its membership's enforcement experience, serving as both investor education and advance warning to securities professionals about prevalent fraud schemes such as affinity fraud, promissory note schemes, and, increasingly, frauds involving cryptocurrency and self-directed digital asset accounts.
Alongside its enforcement and examination functions, NASAA operates a Coordinated Review Program that addresses a very different constituency: small and emerging companies seeking to raise capital across multiple states simultaneously.
Historically, an issuer conducting a multi-state offering faced separate, duplicative filings and potentially inconsistent comments from every state in which it intended to sell securities.
Under the Coordinated Review Program, an issuer submits a single filing that is examined by a small number of lead reviewers on behalf of all participating states, most notably for Regulation A offerings — the exemption that allows smaller companies to raise capital from the public without a full-scale registered offering.
Participating states apply a common set of NASAA policies and work to a standardised review timeline, substantially reducing the time and cost of clearing a multi-state offering compared with negotiating separately with each state administrator. The programme illustrates a less publicised but important dimension of NASAA's work: balancing investor protection with facilitating legitimate capital formation for smaller issuers.
Investor education is a core part of NASAA's mission alongside enforcement coordination and rulemaking. Beyond its annual top threats list, NASAA produces investor alerts, checklists for vetting brokers and investment advisers, and educational materials distributed through its membership to schools, community groups, and senior centres across its member jurisdictions.
Protection of senior and vulnerable investors has become a particular focus of NASAA's model rule programme. NASAA has adopted a model act to protect vulnerable adults from financial exploitation, which member states may enact to empower broker-dealers and investment advisers to delay disbursements from an account when exploitation is suspected, and to permit firms to notify a trusted contact person and, where appropriate, state regulators or adult protective services.
A substantial number of NASAA member jurisdictions have now adopted some version of this model act, making it one of the association's most widely implemented legislative initiatives and a topic increasingly referenced in state law examination content.
NASAA's members operate within the dual federal-state securities regulatory system established by the Securities Act of 1933, the Securities Exchange Act of 1934, and the National Securities Markets Improvement Act of 1996 (NSMIA) — which substantially redrew the boundary between federal and state authority over securities offerings and investment adviser regulation.
Before NSMIA, most securities offerings required registration in every state in which they were sold, in addition to federal registration with the SEC, creating significant duplication for issuers conducting national offerings. NSMIA preempted state registration and review authority over defined categories of "federal covered securities" — principally securities listed on national exchanges and shares of registered investment companies — leaving states with notice filing and fee-collection authority over these offerings rather than full merit or disclosure review. NSMIA similarly divided investment adviser oversight by assets under management, generally assigning advisers below the threshold to state registration and larger advisers to SEC registration.
Under the NSMIA framework state administrators retain full registration authority over state-registered investment advisers managing less than one hundred million dollars, concurrent fraud enforcement authority with the SEC over all persons committing securities violations within the state — a power NSMIA expressly preserved even for otherwise federally preempted securities and advisers — and notice filing authority over federal covered securities.
NASAA represents its members' collective interests before Congress and federal agencies — advocating for the preservation of meaningful state regulatory authority while working collaboratively with the SEC and FINRA on shared concerns, including comment letters on proposed federal rules, joint investor alerts, and coordinated examination sweeps targeting shared areas of regulatory concern.
Candidates frequently confuse NASAA with the SEC and FINRA, but the three organisations occupy distinct roles. The SEC is a federal government agency created by the Securities Exchange Act of 1934 with direct statutory enforcement authority over federal securities law.
FINRA is a self-regulatory organisation, not a government body, responsible for overseeing broker-dealers and their registered representatives and for administering most securities industry qualification examinations.
NASAA, by contrast, is an association of state, provincial, and territorial government regulators — its members individually hold direct statutory enforcement authority under their own state laws, but NASAA itself, as the coordinating association, does not. Understanding this distinction — a membership association of independently empowered state regulators, rather than a regulator or self-regulatory organisation in its own right — is essential to correctly answering examination questions about NASAA's role.
NASAA is tested on the Series 63, Series 65, and Series 66 examinations in the context of state securities regulation, the Uniform Securities Act, the role of state administrators, and the examinations NASAA develops.
The key points to retain are these.
NASAA is a voluntary association of sixty-seven state, provincial, and territorial securities regulators founded in Kansas in 1919 — the oldest international investor protection organisation, predating the SEC by roughly fifteen years.
It has no independent enforcement authority — it coordinates member activities, develops model rules and policy statements, and develops examination content. NASAA develops the Series 63, Series 65, and Series 66 examinations — all administered by FINRA.
State administrators hold broad authority under state blue sky laws — registering broker-dealers, agents, investment advisers, and investment adviser representatives, investigating violations, issuing cease and desist orders, and imposing penalties.
Under NSMIA, state administrators retain full registration authority over investment advisers managing less than one hundred million dollars and concurrent fraud enforcement authority with the SEC over all persons committing violations within their state, regardless of whether the security or adviser is otherwise federally preempted.
NASAA is distinct from both the SEC (a federal government agency) and FINRA (a self-regulatory organisation) — it is an association of independently empowered state, provincial, and territorial regulators, and candidates should not treat the three bodies as interchangeable on the examination.
