Proposal to Reform Continuing Education Requirements
Summary
SIFMA provides comments to Financial Industry Regulatory Authority, Inc. (FINRA) on FINRA Regulatory Notice 18-26: Enhancements under Consideration by the Securities Industry/Regulatory Council on Continuing Education.
SIFMA supports the efforts of the CE Council to enhance the CE Program and is submitting this comment letter to inform the CE Council’s ongoing work.
Excerpt
By Electronic Mail to [email protected]
Re: FINRA Regulatory Notice 18-26: SIFMA Comments on Enhancements under Consideration by the Securities Industry/Regulatory Council on Continuing Education
Dear Ms. Mitchell:
The Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to comment on Financial Industry Regulatory Authority, Inc. (“FINRA”) Regulatory Notice 18-26 (“RN 18-26”), discussing enhancements under consideration by the Securities Industry/Regulatory Council on Continuing Education (the “CE Council”) to the Securities Industry Continuing Education Program (the “CE Program”).
- EXECUTIVE SUMMARY
SIFMA supports the efforts of the CE Council to enhance the CE Program and is submitting this comment letter to inform the CE Council’s ongoing work. As set forth below, SIFMA believes that the CE Council can best further its efforts with respect to enhancing the CE Program by:
- enabling previously registered individuals to maintain their qualification status through participation in an annual continuing education program while outside the securities industry, subject to reasonable eligibility standards;
- allowing training for other programs – such as the annual compliance meeting, anti-money laundering (“AML”), privacy and ethics training, and other credentialing programs – to count toward satisfying the Firm Element requirement of the CE Program;
- restructuring the Regulatory Element requirement of the CE Program to provide registered persons with greater flexibility in selecting content most relevant to their job functions and registration types;
- making topics of the Regulatory Element for the coming year available to firms in advance to support the development of firm training programs to meet the Firm Element requirement;
- creating a centralized content catalog to serve as an additional source of Firm Element content;
- improving the visibility of the CE Council’s guidance and resources;
- combining Firm Element and Regulatory Element training into a single annual learning plan requirement; and
- creating enhanced reporting and automated notification functions within the CRD system and/or the Financial Professional Gateway to notify registered persons of their continuing education obligations and to mitigate the additional efforts required by firms to monitor registered persons’ compliance with annual Regulatory Element requirements