As a financial firm, you’re likely investing in various training programs for your registered representatives throughout the year. But can these existing efforts count towards your Firm Element requirements? This article explores which types of training can qualify, what criteria need to be met, and how to assess if your current programs are sufficient or if additional learning is necessary.

Can Regulatory Element CE count towards our Firm Element CE?

No, this is a different requirement. However, it is wise not to duplicate content. See Council CE’s FAQ for more detail on this topic.

What about AML training and/or your ACM?

FINRA recently amended its rule to allow firms to consider the annual compliance meeting (ACM) or AML training as part of satisfying the annual Firm Element requirement. However, it’s important to note that if your firm’s needs analysis determines you need training on a different topic than what is offered through your AML or ACM, additional training should be offered.

Can insurance license CE or professional designation coursework fulfill Firm Element requirements?

Other CE or training programs may satisfy Firm Element requirements if they cover relevant securities products or regulations. Insurance training on investment-related products can count if identified as appropriate in the needs analysis. Similarly, professional designation coursework can fulfill Firm Element requirements if it adequately covers planned subjects. For more details, consult the CE Council Guide to Firm Element Continuing Education.

Can IAR CE count toward Firm Element CE and vice versa?

Similar to what is stated above, so long as the training covers relevant securities products and regulations and adequately covers topics addressed in the needs analysis, it can count. However, it is important to note that in order for the training to count for IAR CE credit, the content must be approved by Prometric on behalf of NASAA. Training approved for IAR CE credit must be strict criteria established by NASAA.

Understanding Firm Element CE Program Requirements

What should curriculum focus on and how do I know if additional training is needed?

Your Firm Element curriculum should focus on timely and significant topics that are relevant to your firm’s business. There are a wide range of resources you can leverage. After reviewing these resources for what is relevant to your firm’s business, it might be helpful to perform a gap analysis to determine if your Firm Element curriculum covers the subject matter discussed in these materials. Again, focus on the topics most relevant to your firm’s business model. Below are some good resources to reference when determining whether FINRA will find additional training necessary for your firm:

Generally, Firm Element rules require broker-dealers to evaluate and prioritize their training needs annually. This involves conducting an annual needs analysis and developing a written training plan. The plan must consider the firm’s size, organizational structure, scope of business activities, and regulatory developments. If your needs analysis determines that training is needed on a certain topic due to new regulatory developments or shortcomings in a recent audit, additional training should be added.

If a firm’s analysis establishes the need for supervisory training for persons with supervisory responsibilities, such training must also be included in the firm’s training plan.

Training programs used by firms to implement their training plans must, at a minimum, cover topics related to the roles, activities, and responsibilities of their registered persons and to professional responsibility. Firms must also maintain records documenting the content of their training programs and completion of the programs by their registered persons.

What’s Next?

What are some good resources for building Firm Element curriculum? For comprehensive guidance, refer to the CE Councils detailed FAQ section found here. And of course, don’t forget to check out Quest CE – your go-to solution for creating and managing top-notch Firm Element programs that meet all regulatory requirements, while providing engaging and effective training for your representatives! To learn more about our Firm Element CE offerings, click here.