The CE Council recently released a guide to Firm Element Continuing Education Program. The guide is intended to generate ideas for producing a Firm Element program that not only meets regulatory requirements, but also provides training that is topical, spurs interest from the audience, and fosters conversation amongst all stakeholders.
Due to the sheer volume of the guide, Quest CE has broken the report into three sections. This blog is intended to cover the Firm Element requirement, in general, to help generate ideas for producing an effective Firm Element training program.
Click the links below to navigate to other sections of the guide.
Firm Element Program
According to rules and regulations of various self-regulatory organizations (SROs) of the securities industry, firms are required to establish an annual Firm Element program for their covered registered persons that enhances their securities knowledge, skills and professionalism. Provided below are some key considerations when building your Firm Element program.
Firm Element programs must encompass the following components:
- needs analysis;
- written training plan;
- all covered registered persons; and
- books and records maintenance.
Additionally, Firm Element programs must cover the following standards:
- ethics and professional responsibility; and
- securities products, services and strategies offered by the firm.
A firm should identify the person(s) responsible for overseeing the Firm Element program; developing, implementing and maintaining its core components; and ensuring it evolves with the business, industry trends and the progress of the covered persons.
These responsibilities include:
- performing the needs analysis;
- developing and implementing the written training plan;
- establishing the time frame and schedule to deliver training;
- documenting course titles, content and participation;
- retaining training-related documents for books and records;
- managing the annual process of updating the needs analysis and written training plan;
- reviewing training objectives and modifying as needed (e.g., quarterly or biannual review or ad hoc modifications due to unforeseen regulatory concerns); and
- establishing and maintaining the firm’s policies and procedures to meet CE requirements.
Firm Element Best Practices
In addition to the detailed guidance provided above, the CE Council urges firms to consider the following checklist of best practice considerations when developing their Firm Element programs:
1.) Encourage senior management to establish “Tone from the Top” messaging on the value of the Firm Element program and the firm’s low tolerance for non-compliance.
2.) Confirm that training programs and materials meet standards for content stipulated in the rules and regulations of the securities industry.
3.) Use training sessions to highlight the importance and reasons for continuous education and training of covered registered persons.
4.) Perform a quality assurance review of the Firm Element program, including course content and processes, against regulatory requirements.
5.) Educate covered registered persons and senior management about the importance and value of Firm Element, as well as the fact that it is mandatory.
6.) Expand the scope of the Firm Element program to include associated persons.
7.) Ask the firm’s internal audit department, compliance department, or compliance officer to periodically review the firm’s compliance with its Firm Element requirements, in addition to conducting ongoing reviews of the Firm Element processes and programs.
8.) Diversify breadth of training topics and avoid limiting courses based solely on role or function.
9.) Leverage training material offered in other financial industries (e.g., insurance and financial planning) if courses are consistent with the topics identified in the needs analysis and may support the professional development of the individual.
10.) Firms may consider training relating to their anti-money laundering (AML) compliance program and annual compliance meeting toward satisfying an individual’s annual Firm Element requirement.
11.) Identify learning content to improve compliance with firm policies and securities laws.
12.) Provide disincentives for late completion of Firm Element training
To read the complete guide, provided by the CE Council, click here.
To learn more about Quest CE’s Firm Element program, click here.
To learn more about how to customize Quest CE’s Firm Element content to fit the specific needs of your firm, using our course editor tool, Course Builder, contact our sales team today at sales@questce.com.
