Investment Adviser Representatives (IARs) and firms managing registered investment advisers: take note. The December 31, 2024 deadline for IAR Continuing Education (CE) is fast approaching. Understanding the implications of missing this deadline is crucial for your professional standing.

This article explores the potential ramifications of not completing your CE credits on time, including the ‘CE Inactive’ status and its visibility to the public. We’ll also examine what happens if you fall behind on your educational requirements for consecutive years, and how this might impact your registration across different states.

What if I fail to complete my IAR CE credits by December 31, 2024?

Should an IAR miss their continuing education deadline, they’ll need to cover the registration renewal cost, and their designation will shift to ‘CE Inactive’ in the CRD (the IAR can continue to do business in this status). This “CE Inactive” label pops up in all states requiring IAR CE and shows up on IAPD and BrokerCheck for anyone to see.

The ‘CE Inactive’ label alerts the IAR that wrapping up their educational requirements before the year closes is crucial. Failing to do so could jeopardize their ability to renew their professional credentials, if not done by December 31st. The “CE Inactive” status sticks with them across all the states following this model.

Failure to Satisfy CE Requirements for Two Consecutive Years After Annual Deadline

The IAR’s registration will be terminated and their CRD status will change to “IAR CE Fail to Renew” in all states implementing the CE rule. To regain registration, IARs must make up the deficient CE and submit a new Form U4 for consideration. This underscores the critical nature of ongoing CE compliance for maintaining professional credentials.

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 Meaning
IAR CE Not Required Approved  The individual does not have an IAR CE requirement to fulfill this year.
IAR CE Required Approved  The individual has an IAR CE requirement to fulfill this year.
IAR CE Satisfied Approved 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.