Q1 and Q2 are usually when firms find themselves ready to strategize what elements need to be covered in the new year’s Firm Element CE program. Since this is something that most only focus on once a year, chances are you may need a refresher on all the things you need to get done, or have worked through, before training ever gets assigned to your firm members. So where should you begin, then?
Before diving into the fun stuff (i.e., which specific courses to add to your reps roster), it’s important to remember that firms are required by FINRA Rule 1240 to complete a Needs Analysis before moving on to the rest of their training program. This annual requirement is designed to lay out the specific needs of each firm to identify which training is needed for the year.
What a Needs Analysis…Well, Needs:
- A description of your firm;
- Size, organizational structure, and scope of business including, the types of investment products, services, or strategies offered, or planned to be provided by your firm
- A review or consideration of current market and economic conditions affecting investment products or services provided by your firm;
- A review or consideration of current legal and regulatory developments;
- A review or consideration of trends of customer complaints, regulatory inquiries, arbitrations, litigations, or other forms of disciplinary
proceedings involving any of your firm’s employees; - Feedback and input on critical issues from your firm’s legal, compliance, trading, internal audit, operations, management, and sales personnel;
- A review or consideration of sales and marketing strategies for products and services, with attention to related suitability issues, product risk, and other regulatory concerns;
- The use of performance reviews and business plans to identify the development needs of individuals or groups of persons within your firm; and
- Aggregate feedback received from the Regulatory Element.
After establishing your Needs Analysis, it’s time to create your Written Training Plan. Like the Needs Analysis, this is also a required step to be completed before putting together the rest of your program. A training plan is where you map out the specifics of what your training program will accomplish for your reps.
What your Written Training Plan Should Address:
- The overall objective of the training program;
- The knowledge or skills to be imparted;
- Specific training programs or activities;
- The classifications of individuals to receive training;
- The specific delivery mechanism and resources needed to conduct the training;
- The specific time scheduled for delivery; and
- Feedback to evaluate the program’s effectiveness and modifications.
With these two steps completed, you are now ready to move on to the rest of your training program. For more details about both the Needs Analysis and Written Training Plan, a detailed version of FINRA’s guidelines can be found here.
If you need help launching a needs analysis survey, creating a written training plan, or finding relevant training for your firm members, our team is eager to help! Find more information about our services here.
