FINRA Issues Suspension Over Firm Element Training

In this month’s FINRA Disciplinary Actions Notice, a registered representative from Aliso Viejo, California was suspended from association with any FINRA member in any capacity for three months due to the entry of findings that she instructed her assistant to complete her Firm Element continuing education coursework on her behalf. In light of the representative’s financial status, no monetary sanction was imposed.

FINRA Rule 1250 requires member firms to maintain a continuing education program for their registered persons. The Firm Element requires broker dealers to establish a formal training program to keep “covered” registered persons current on job and product related subjects. Registered persons who are included in the member’s written training plan must take all appropriate and reasonable steps to participate in continuing education programs as the firm requires.

The firm, in turn, must maintain records documenting the content of the programs and completion of the programs by covered registered person. A registered person violates FINRA Rule 2010 when that person directs or allows someone else to complete his or her continuing education requirements.

The company’s Firm Element continuing education program required the representative to complete certain computer-based educational modules no later than November 30th. In mid-November, the representative asked her assistant to complete her Firm Element continuing education. On November 30th, she reminded her assistant to complete the continuing education.  Later that day, her assistant used her administrative login name and password to complete her Firm Element continuing education requirement.

To read the complete December FINRA disciplinary actions notice, click here.