As we approach the final days of 2024, compliance officers must ensure their firms complete three critical CE requirements before December 31st: Firm Element CE, Regulatory CE, and IAR CE. This guidance document outlines your oversight responsibilities for each requirement.
Regulatory Element
Deadline: December 31, 2024
Who it Impacts: FINRA Rule 1240 requires all registered persons to complete the Regulatory Element annually for each registration they hold. As a compliance officer, you should verify that the 2024 CE Regulatory Element courses have been assigned and completed. Pay particular attention to personnel who have added or dropped registrations, as these changes may alter their required coursework.
Where to Take: All registered persons must access their assigned courses through the Financial Professional Gateway (FinPro). Your role includes ensuring all registered persons have current FinPro accounts with accurate contact information.
To create a FinPro account, click here.
Consequences for Failing to Comply: Registered persons who fail to complete their Regulatory Element requirement by the annual deadline will be automatically designated as CE inactive by FINRA. Firms may request that FINRA extend the time by which a registered person must complete the Regulatory Element for good cause shown.
Monitoring CE Obligations: As a compliance officer, you have access to Annual Regulatory Element templates in FINRA Gateway Reports. Establish a regular monitoring schedule to track completion status across your organization. Document your monitoring efforts and any follow-up actions taken.
Firm Element
Deadline: December 31, 2024
Who it Impacts: Your firm’s CE program must encompass all registered persons. As the compliance officer, you are responsible for ensuring your firm maintains comprehensive documentation of its CE program, including the annual evaluation of training needs and a detailed written training plan.
The training plan under your supervision must reflect your firm’s specific characteristics, including size, organizational structure, and scope of business activities. Your analysis should incorporate regulatory developments and registered persons’ performance in the Regulatory Element. For firms requiring supervisory training, ensure these components are clearly documented in your training plan.
Where to Take: While FINRA provides flexibility in training delivery methods, your primary responsibility is ensuring proper documentation of the Needs Analysis, Written Training Plan, and training administration. Maintain detailed records of completion and be prepared to demonstrate the effectiveness of your chosen training methods.
To learn more about how Quest CE can help you launch a Firm Element training program to your firm members, click here. To view Quest CE’s full Firm Element course catalog, click here.
IAR CE
Deadline: December 31, 2024
Who it Impacts: For registered investment advisers in states that have adopted the IAR CE model regulation, you must take:
- 6 credits in Products and Practice
- 6 credits in Regulatory and Ethics
Where to Take: Investment advisers have an assortment of options to take their IAR CE credits through. To visit Quest CE’s IAR CE e-commerce platform click here. To learn more about launching a firm-sponsored IAR CE program, click here.
Consequences for Failing to Comply: An IAR’s failure to complete CE requirements by December 31st triggers several compliance concerns. The individual will be required to pay their registration renewal fee, and their status in CRD will change to “CE Inactive.” This status appears in both Investment Adviser Public Disclosure (IAPD) and BrokerCheck, potentially affecting your firm’s reputation and operations. Moreover, incomplete CE requirements can prevent registration renewal for the following year.
To learn more about the consequences of an IAR’s failure to complete requirements by December 31st, click here.
Compliance Officer Action Items
Your immediate priorities should include:
- Conducting a comprehensive audit of completion status across all CE types
- Implementing a communication strategy for non-compliant registered persons
- Documenting all oversight activities and interventions
- Preparing contingency plans for last-minute completion issues
- Establishing a final verification process for December 31st
Remember that your oversight of these CE requirements is fundamental to maintaining your firm’s regulatory compliance. Early intervention and systematic tracking will help prevent last-minute compliance issues and ensure a smooth transition into the new year.
