Registration of Professionals

IAR Continuing Education

On February 28, 2022, Wisconsin published new rule DFI−Sec 11, which sets out continuing education requirements for investment adviser representatives (IARs). These requirements go into effect January 1, 2023, which means Wisconsin registered IARs will begin taking and reporting CE credits in 2023.

This new rule represents the culmination of years of work by the North American Securities Administrators Association (NASAA), its members (state securities regulators), and industry to develop a relevant and responsive IAR continuing education program. This CE program will promote heightened regulatory compliance while also helping investment adviser representatives better serve their clients by remaining knowledgeable of current regulatory requirements and best practices.

To learn more about NASAA and its mission, please visit nasaa.org.

IAR CE Requirements

Each IAR will need to attain 12 CE credits each year to maintain their IAR registration. The 12 credits must include 6 credits of Products and Practices and 6 credits of Ethics and Professional Responsibility. The mandatory CE program will apply to all registered IARs of both state-registered and federal covered investment advisers. IARs will self-manage selecting and completing courses, which will enable them to tailor their CE to their interests and business models. Courses are offered by NASAA approved course providers, which can be found on NASAA’s website.

Financial Professional Gateway (FinPro)

FINRA’s Financial Professional Gateway (FinPro) provides individuals (current or former representatives) direct access to resources and tools to manage their securities registration information and a platform to monitor their continuing education requirements. FinPro is an important tool for IARs because it provides them with a mechanism to view courses taken and the progress towards completion of their annual CE requirement. Since IARs are responsible for ensuring their CE vendor reports completion of CE, they may find FinPro useful for tracking and monitoring CE.

Features of FinPro:

• Track and monitor CE
• View CRD record
• Schedule an exam
• Review/download last U5

An instructional guide to set-up a FinPro account can be accessed on FINRA’s website.

Additional FinPro questions? See FinPro’s list of FAQs.

FAQs

Who must comply with the IAR CE requirements?

Every IAR registered in Wisconsin must comply with IAR CE requirements. The program applies to all registered IARs of both state-registered and federal covered investment advisers.

When do IARs need to begin complying with the IAR CE requirements?

IARs registered in Wisconsin as of January 1, 2023, must begin taking CE courses in 2023, and obtain the required 12 credits by December 31, 2023.

When an individual registers for the first time as an IAR, they will not be subject to the CE requirements until the next calendar year. Similarly, if an IAR is registered only in states without a CE requirement and becomes registered in a CE state for the first time, that IAR will not need to comply with those CE requirements until the next calendar year. For example, if an IAR has not been registered in any states requiring CE and registers in Wisconsin during 2023, that IAR will not begin complying with the CE rules until 2024. However, IARs who are already registered in an IAR CE state prior to registering in Wisconsin must continue to complete their CE credit schedule for that calendar year. See “What if an IAR is registered in more than one state?” FAQ below.

How many credits/hours are required?

Beginning in 2023, IARs will need to obtain 12 CE credits each year to maintain their IAR registration.

The 12 credits must include:

• 6 credits of Products and Practices and
• 6 credits of Ethics and Professional Responsibility

Generally speaking, an IAR cannot receive credit more than once for the same course and must take care to avoid duplicate courses in subsequent years. (An exception to this is a course that is updated and receives a new course number.)

Where can IARs find a list of approved course providers?

To obtain credit, courses must be approved for the CE program. A list of approved providers can be found on the NASAA (North American Securities Administrators Association) website.

What if an IAR is registered in more than one state?

An IAR registered in more than one state must comply with the requirements of each state securities regulator. However, per rule DFI−Sec 11, an IAR is considered in compliance with Wisconsin’s CE requirements as long as both of the following are met:

   1. The IAR's home state (where the IAR has their principal office and place of business) has adopted IAR CE requirements that are at least as stringent as Wisconsin’s; and

   2. The IAR is in compliance with their home state requirements.

If an IAR already maintains CE credits for certain professional designations, can those be used to fulfill Wisconsin’s IAR CE requirements?

Yes, credits from CE courses taken to maintain professional designations can apply to the IAR CE program so long as the provider and course have been approved through Prometric for IAR CE purposes. Providers will likely promote the fact that certain courses qualify for IAR CE so IARs can look for courses that meet the CE requirements for both IAR CE and their professional designations.

For dually registered IARs, can the CE required by FINRA for BD agents be used to fulfill any of the CE requirements for IARs?

Yes. An IAR who is also a registration Broker Dealer (BD) agent and who complies with FINRA's CE requirements is considered to be in compliance with the requirement to report six credits of Products and Practices content, so long as the FINRA CE content continues to meet certain baseline criteria as determined by NASAA and payment is made in CRD of a $3 per credit reporting fee.

What happens if an IAR does not complete the CE requirements in a timely manner?

If an IAR does not complete the CE requirement by the annual deadline, the IAR will pay the registration renewal fee and CRD will set their IAR CE status to "CE Inactive." Current CE status will also appear in the Investment Adviser Public Disclosure (IAPD) and BrokerCheck. The IAR can continue to do business, however, if CE is not completed by the end of the second year, the IAR will be unable to renew their registration and it will be terminated for failing to complete CE.

If you have additional questions, please visit NASAA’s IAR CE webpage or their full list of FAQs; or call us at 608-266-2139.