With just a few months remaining in 2023, a pivotal question arises: have you satisfactorily fulfilled your Investment Adviser Representative (IAR) Continuing Education (CE) obligations for the year?
Although twelve months can seem like ample time to complete your requirements, time moves quickly – and too often those credits get pushed to the backburner. As we head into the fall months and end of year approaches, it’s important to check in with yourself and make a plan to finish off the year strong.
Today, we’re doing a quick refresher of the 2023 requirements, as well as a few resources that can help you complete your IAR CE by year’s end.
What are the IAR CE credit requirements?
In November 2020, the North American Securities Administrators Association (NASAA) introduced a rule that allowed states and recognized jurisdictions to implement continuing education requirements, the first of which began rolling out in 2022.
Under the IAR CE rules, advisers need to complete 12 credit hours through an approved course. Those 12 hours are split into two categories: six hours of Products and Practices and six hours of Ethics and Professional Responsibility. Note that advisers cannot repeat a course for credit, even if the same course is taken in separate calendar years.
The course vendors are responsible for reporting and submitting credit hours earned to the Financial Industry Regulatory Authority (FINRA), NASAA’s vendor for program tracking. However, you can monitor your progress through FINRA’s FinPro system.
Note: Not sure how many credits you have left for 2023? Sign up for or login to your FinPro account to view your progress and ensure all your credits have been properly reported. Click here to access FINRA’s guide to account sign up.
Who needs to fulfill the requirements?
NASAA provides a list of states that have passed IAR CE requirements, which is updated as new information becomes available. As of August 2023, the list stands as follows:
State | Effective Date |
Arkansas | 1/1/2023 |
Colorado | 1/1/2024 |
Florida | 1/1/2024 |
Kentucky | 1/1/2023 |
Maryland | 1/1/2022 |
Michigan | 1/1/2023 |
Mississippi | 1/1/2022 |
Nevada | 1/1/2024 |
North Dakota | 1/1/2024 |
Oklahoma | 1/1/2023 |
Oregon | 1/1/2023 |
South Carolina | 1/1/2023 |
Tennessee | 1/1/2024 |
Vermont | 1/1/2022 |
Washington, D.C. | 1/1/2023 |
Wisconsin | 1/1/2023 |
NASAA also provides an interactive map of the above states.
Note: If you’re registered in more than one state, you’ll need to fulfill requirements set forth by both states. For example, if you’re registered in New York and Maryland, you’ll have to complete the 12 IAR CE to meet Maryland’s standard even though New York has no such standard.
What happens if IARs don’t fulfill the CE requirements?
If you have fallen behind on your credits and feel you won’t be able to complete them in time for 2024, it’s not cause for immediate panic. NASAA does allow advisers to make up missed credits in the year following (i.e., if you’re a credit short for 2023, you can make up that credit in 2024). Note that any “missed” credits will need to be fulfilled before you can start working toward the next year’s credits.
Although advisers are allowed to make up credits should they fall behind, it’s not advisable. For one, if you struggled to fit all 12 credits into a calendar year, expecting to complete even more next year is likely unrealistic.
Additionally, regulatory bodies can choose to suspend registration should you fail to complete the required credit hours. Those wishing to keep their registration intact will need to prioritize completing credits on time.
Note: Extra credits will not “roll over” into the next year (i.e., completing 14 credits in 2023 does not mean you have a head start on your 2024 credits).
Resources for completing your 2023 IAR CE credits
All IAR CE credit courses must be provided through a NASAA-approved vendor. The regulatory body provides a list of such vendors through their site, which is updated regularly.
The problem with that lengthy list? Many advisers aren’t sure where to begin. In a rush to finish up your credits, contacting and finding a CE schedule for each vendor can seem exhausting. That obstacle is compounded by the fact that several of these vendors only provide CE credit course options to their internal staff or to certain firms.
Additionally, many providers only offer courses at certain times, providing the CE sessions either in-person or online as a live event. For advisers with busy schedules, it can be tough to fit those into your time.
Online course options
The solution lies in online IAR CE course options, such as those offered through the MyRIACompliance platform. This platform provides a plethora of on-demand course options that you can take at your own pace and on your own schedule, each created by former regulators, compliance consultants and cybersecurity experts.
There are courses available for both the Products and Practices and Ethics and Professional Responsibility requirements, as well as complementary courses and materials for further learning. RIA in a Box will report your course completion directly to the FINRA tracking system, and also gives you a look at your progress through the MyRIACompliance platform.
Even as 2023 heads into its final months, you still have time to complete your IAR CE credits and stay on top of your registration requirements.
Complete your IAR CE
Want to complete your registration requirements on your own time? Click here to explore RIA in a Box’s IAR Continuing Education solution and get started today.