19 October 2021
Main Contributor: Zachary Fenno, CSCP, Compliance Manager
In November 2020 the North American Securities Administrators Association (“NASAA”) adopted a Model Rule, setting guideline requirements for investment advisor representatives (“IARs”) registered with investment advisory firms to complete continuing education requirements in order to maintain licenses in jurisdictions that adopt the rule. This will apply to both state and federally registered advisors.
IARs will need to complete twelve (12) credits annually. Six (6) credits must be for Products and Practices and six (6) credits must focus on Ethics and Professional Responsibility.
NASAA has only provided standard guidelines for IAR Continuing Education requirements. It will be up to each state to decide whether they want to adopt these rules, create similar rules, or decide not to adopt any continuing education requirement.
So far, Mississippi is the only state to adopt these guidelines and all IAR’s registered in Mississippi will be required to complete continuing education requirements starting January 1, 2022. Michigan, Nevada, Vermont, and Wisconsin are in the process of adopting the guidelines, but they will not be officially implemented until at least January 1, 2023.
WHAT DO YOU NEED TO DO?
In order to prepare for these gradual requirements, we suggest you create a matrix listing your IARs and each state in which they are registered. Review NASAA’s site, at least annually, for updates on states that are implementing these rules and keep an eye out for any other state announcements for those states that may not adopt these specific guidelines. Of course, you can always call us!