The NASAA Regulatory Services team is reminding all investment advisers that this is the first year an IAR could fail to renew their license as a result of IAR CE non-compliance. As a reminder, if an IAR goes two consecutive years without fulfilling their annual CE requirement, he or she will lose their license in all IAR CE states the first week of the new year. Please be mindful that this also includes their licenses with all of the states that adopted with a 2024 effective date.
For example, if an IAR was licensed with Maryland and Florida in 2022, dropped their Maryland license, and did not complete their 2022 CE, he or she will lose their Florida license the first week of 2024 unless it is completed and submitted by December 31st.
What if I fail to complete my IAR CE credits by December 31, 2023?
If you failed to satisfy your IAR CE requirement for one year (12 credits), your registration status will update to “Approved – Pending IAR CE” in all IAR CE states. You will be required to catch up on your deficient IAR CE which is 12 credits plus the current year’s requirement of 12 credits and then annually thereafter.
If you failed to satisfy your IAR CE requirement for two consecutive years, your registration will fail to renew in all IAR CE states. You will be required to catch up on your deficient IAR CE before resubmitting your U4 for state registration. You will then be required to complete 12 credits of IAR CE annually thereafter.
This is especially important for advisers in states like Mississippi, Vermont, and Maryland as these states all adopted in 2022 and therefore will have required two years of consecutive CE by this December.
What if I dropped my registration with a state that required IAR CE?
IAR CE requirements are still maintained if an IAR has been registered with a state that requires IAR CE (an in-scope state) for any part of the year. Thus, even if an IAR withdraws from an in-scope state, the requirement continues to exist and may affect future registration(s) in in-scope states, as outlined by the example provided above.
What are the different IAR Registration Statuses?
|IAR CE Status
|IAR Registration Status
|IAR CE Not Required
|The individual does not have an IAR CE requirement to fulfill this year.
|IAR CE Required
|The individual has an IAR CE requirement to fulfill this year.
|IAR CE Satisfied
|The individual has satisfied the IAR CE requirement for this year and is current on their IAR CE obligations.
|IAR CE Inactive
|Approved-Pending IAR CE
|The individual did not complete their IAR CE requirement for the previous year.
|IAR CE Fail to Renew
|Terminated-No IAR CE
|The individual did not complete their IAR CE requirements for the previous two years, causing the individual’s IAR registration(s) for which there is a CE obligation to be administratively terminated. To reactivate the impacted IAR registrations, the individual must make up the required CE or re-qualify by examination and then reapply for registration.
For more details, visit NASAA’s website here.