To help compliance teams strengthen their Firm Element CE programs and avoid common regulatory pitfalls, Quest CE recently hosted a live webinar, Developing FINRA-Ready Firm Element CE Programs. The session provided attendees a practical walkthrough of the key requirements and common missteps that firms face when it comes to compliance. To watch a recording of our webinar, click here.

Laying the Foundation: What FINRA Expects

The session opened with a foundational overview of the Firm Element requirement under FINRA Rule 1240(b), focusing on its three core components: the annual needs analysis, a written training plan, and supporting books and records. While these are well-defined at a high level, many compliance teams struggle with the practical steps needed to build a tailored, risk-based training program.

To help guide content selection, the panelists emphasized that training should address ethics and professional responsibility, as well as the securities products, services, and strategies offered by the firm. That includes topics such as general investment risks, suitability considerations, and applicable regulatory requirements. Attendees were encouraged to review FINRA’s Regulatory Element topics, exam priorities, and recent disciplinary actions to identify emerging focus areas and align training accordingly.

Quest CE also shared resources highlighting the most popular Firm Element courses of 2025 and newly released content, helping firms explore what their peers are prioritizing as part of their own CE strategies.

Common Exam Pitfalls (and How to Avoid Them)

Drawing from recent FINRA exam findings, the presenters identified three of the most frequent compliance failures when it comes to Firm Element CE:

  • Failing to conduct or document a training needs analysis.
  • Incomplete or missing supervisory procedures tied to training completion.
  • Delivering content that does not align with the needs identified in the analysis.

To avoid these issues, compliance leaders were encouraged to take a risk-based approach: incorporate regulatory developments, internal investigations, customer complaints, and cross-department input when developing the annual training plan. The webinar also emphasized the importance of oversight—automated reminders, management visibility, and clear accountability all help reinforce a strong compliance culture.

Peer Best Practices: What Leading Firms Are Doing

The session also covered several effective strategies used by high-performing compliance teams, such as:

  • Extending CE to include supervisory and support roles, not just registered reps.
  • Incorporating broader topics like cybersecurity, ethics, and elder exploitation.
  • Using outside content from related industries when relevant to firm-specific risks.

These examples reinforced that strong Firm Element programs are integrated, flexible, and tailored—not just routine check-the-box efforts.

As FINRA continues to emphasize the importance of Firm Element in its examination program, compliance teams must treat CE planning as a living, strategic process, not just a regulatory requirement. By understanding where firms commonly fall short and applying best practices from peers, we hope you’ll be able to build stronger, more defensible programs that support both regulatory readiness and firm-wide risk management.

Want to See the Demo?

The webinar wrapped with a quick look at Quest CE’s Course Builder—our tool that allows compliance teams to quickly customize any of Quest CE’s off-the-shelf training courses to align with their firm’s needs analysis and policies.

To schedule a personalized demo, reach out to us here.