Happy Renewal Season!!! As year-end 2024 approaches, it’s a great time to review the Investment Adviser Representative Continuing Education (IAR CE) status for your associates required to satisfy this annual requirement. IARs who fail to satisfy their IAR CE requirement for two consecutive years risk being administratively terminated in jurisdictions that have implemented an IAR CE requirement unless they satisfy ‘at a minimum’ the full 2023 requirement before year-end 2024. Although not rocket science, there are some complexities around the unique nature of the IAR CE program that still creates some confusion for the industry.
For example, it’s important to consider the December 26th CRD/IARD renewal shutdown. Although IARs will be able to take IAR CE courses during the shutdown period and CE providers will be able to continue to roster credits to FINRA during the shutdown, the individual IAR’s CE Status will not be updated in the CRD/IARD systems to reflect those credits until the systems are brought back online in January 2025 after the year-end renewal season. This shutdown period is of particular concern for IARs who still have not satisfied their 2023 IAR CE requirement as they will fail to renew if their 2023 requirement is not satisfied before the December 26th shutdown.
In addition to the shutdown, IAR’s also need to consider the time it takes for the IAR CE provider to roster the credits after the course has been completed; troubleshoot any unexpected issues that may arise; and for the IAR’s CE Status in CRD/IARD systems to be updated reflecting satisfaction of the requirement prior to the renewal shutdown. RegEd strongly encourages IARs to satisfy their IAR CE requirement by mid-December each year to avoid unexpected and unpleasant consequences.
There are numerous consequences for failing to renew, so this should be avoided if at all possible. Following are some examples of consequences an IAR may face for failure to satisfy IAR CE in time for their CE Status to reflect “satisfied” before the shutdown:
- IARs would no longer be qualified to conduct advisory services in jurisdictions where they no longer hold registrations.
- If the IAR’s resident state is a jurisdiction that fails to renew, the IAR would be unable to perform investment advisory services entirely beginning in 2025 until re-registered.
- Because they are no longer registered, firms may need to reassign the IAR’s clients to other appropriately registered IARs so those clients can continue to be serviced.
- To become re-registered, the IAR must catch up their deficient IAR CE (at least their 2023 requirement as the program permits being behind one year); pay the applicable registration fees again and file a Form U4 amendment requesting to be re-registered.
- Once re-registered, the clients that may have been reassigned to another IAR temporarily will need to be moved again (not a good look from a client-perspective).
- The investment advisory firm may issue discipline to the IAR for failure to remain compliant.
- If the IAR paid to renew the registrations that were ultimately administratively terminated for failure to satisfy IAR CE, they will likely struggle to get those renewal fees refunded to them.
How RegEd Can Help
As an approved provider of Investment Adviser Representative Continuing Education (IAR CE) courses, RegEd has a number of new courses for registered IARs of state-registered and federally covered investment advisers subject to the NASAA model rule. Visit our course catalog to view our full list of available training courses.
Below are some of the new courses for 2024:
Newly Released IAR CE Training Courses
- Diversification, A Practical & Ethical Approach (2 credits Ethics) (IAR_3370)
- Investment Adviser Representative: IAR Senior Protection: Ethical Sales & Account Practices (1 credit Ethics) (IAR_3963)
- Investment Adviser Representative: Ethical Business Practices & the Modernized SEC IA Marketing Rule (1 credit Ethics) (IAR_3971)
- Investment Adviser Representative: Using Artificial Intelligence Ethically (1 credit Ethics) (IAR_3988)
- IARCE E&PR: Ethics of Recognizing Diminished Capacity (1 credit Ethics) (IAR_3877)
- Ethical Guidance in Difficult Markets (2 credits Ethics) (IAR_3357)
- Investment Adviser Representative: What Clients Need to Know: Partnering for Retirement Planning (3 credits Products & Practices) (IAR_3433)
- Alternative Investments: Overview of Various Products (1 credit Products & Practices) (IAR_3028)
Available in October 2024*
- Section 529 Plans (1 credit Products & Practices) (IAR_3529)
- Variable Annuities: Features, Benefits & Risks (1 credit Products & Practices) (IAR_3030)
*IAR CE courses are subject to approval by NASAA
About the Author
Margie Webber
Margie Webber is the Director, Regulatory Compliance BD/IA at RegEd, Inc. For questions concerning the IAR CE requirements, please contact Margie at Margie.webber@reged.com.
About RegEd
RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.
Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.
Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.