The CE Council recently released a guide on proper practices regarding Firm Element Continuing Education. 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 this guide, Quest CE has broken it down into three sections. This blog is intended to cover the Needs Analysis, the first step in developing a Firm Element program is to analyze a firm’s training needs.

Click the links below to navigate to other sections of the guide.

Needs Analysis

According to the CE Council, the needs analysis identifies potential training opportunities for the firm’s covered registered persons and serves as the starting point for developing a written training plan. When conducting a needs analysis, firms should be as specific as possible. The needs analysis should address a firm’s products, services and business model, bearing in mind the demographics of its customer base.

The needs analysis should be well documented and include the various factors considered in identifying the training needs. Below are suggested considerations to help a firm perform the needs analysis:

Firm Structure:

– Business model, job functions and the required knowledge, skills and responsibilities
– Changes to the firm’s structure and supervision framework
– Knowledge and experience level of the firm’s covered registered persons
– Customer base and level of sophistication
– Location(s) and jurisdiction(s) of the firm’s covered registered persons

Firm Policies & Procedures:

– New and updated firm policies and procedures
– Products and services offered and any changes to features or processes
– New products and services offered
– Complexity and risks of products and services
– Changes in market conditions that may impact products and services offered by the firm
– New technology or operational processes
– Marketing strategies that may impact the firm’s sales practices considering best interest and suitability obligations

Regulatory Laws, Rules & Regulations:

– Annual regulatory examination priority letters
– Regulatory sweep letters
– Applicable changes to securities industry laws, rules and regulations
– Clearing firm notifications and frequent surveillance exceptions
– The firm’s quarterly FINRA CE Regulatory Element performance report

Regulatory Actions:

– Regulatory actions and examination findings against the firm and its covered registered persons
– Securities industry regulatory actions, notices and news releases

Customer Complaints:

– Incidents of customer complaints, litigation and arbitrations
– Internal investigations and terminations for cause of the firm’s associated persons
– Review findings and remediations from internal audits, compliance testing, operational risk and control assessments, and operational losses or near misses (e.g., incidents that could have led to monetary loss)

Input from Business Partners:

– Heads of business departments, product sales, operations, internal audit, privacy office, cyber security office, supervision, risk management, legal, compliance

CE Council Firm Element Advisory:

Available online at:

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, using our course editor tool, Course Builder, contact our sales team today at