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NASAA Adopts Investment Adviser Representative Continuing Education Model Rule

May 18, 2022
Woman learning about modified Series 52 Exam on her laptop

The recently-adopted and newly-implemented Continuing Education Model Rule for Investment Adviser Representatives (IARs) has multiple implications and effects for professionals throughout the financial services industry. Read more about the IAR Continuing Education (CE) Model Rule, who it will impact, where it is in effect, related requirements, and more.

What is Investment Adviser Representative Continuing Education (IAR CE?)

IAR CE is an annual continuing education requirement for IARs governed by the NASAA Model Rule on Continuing Education which was adopted in 2020 and implemented by states and jurisdictions beginning in 2022.

Why was the IAR CE Model Rule adopted? 

NASAA’s membership, with strong industry support, adopted the IAR CE Model Rule to address the lack of a continuing education requirement for IARs in contrast to other financial services professionals. These types of professionals are often required to maintain or expand their level of knowledge and competence after initial qualification, which is what the IAR CE Model Rule will now accomplish for IARs.

Who is the IAR CE for?

Any Investment Adviser Representative (IAR) who is registered in a state or jurisdiction that has adopted the NASAA IAR CE Model Rule will be subject to its new CE requirements.

FINRA and IAR CE

For dual registrants, IARs who are also registered agents of BD firms, completion of the FINRA CE Regulatory Element may be applied to meet the Products and Practices component of the IAR CE requirement.  NASAA will accept the Regulatory Element taken in 2020, 2021, and 2022 as an equivalent of the six credits for Products and Practices for 2022.

FINRA CE Firm Element training may also be applied to meet the IAR CE requirement if the training is approved by NASAA.

Professional Designation CE courses (CFP®, ChFC®, CFA®, PFS, CIC) are also eligible for IAR CE credit as long as they are approved by NASAA.

When does the IAR CE Model Rule go into effect?

The IAR CE Model Rule has gone into effect beginning in 2022 in the states that adopted the Model Rule by December 31, 2021.  These are Mississippi, Vermont, and Maryland.

State by state: Where is the IAR CE Model Rule in effect?

IARs registered in 3 states (MS, MD, and VT) must complete their IAR CE requirement by December 31, 2022.  Michigan, Wisconsin, Kentucky, and Oklahoma have adopted the Model Rule in 2022, which means IARs registered in these states will need to complete IAR CE starting on January 1, 2023.  As of May 2022, all other states listed have legislation pending to adopt the Model Rule.

Which states is the IAR CE Model Rule in effect

State

Status

Effective Date

Mississippi

Adopted

January 1, 2022

Vermont

Adopted

January 1, 2022

Maryland

Adopted

January 1, 2022

Michigan

Adopted

January 1, 2023

Wisconsin

Adopted

January 1, 2023

Kentucky

Adopted

January 1, 2023

OklahomaAdoptedJanuary 1, 2023

Arkansas

Pending

TBD

Nevada

Pending

TBD

Washington DCPendingTBD

 

IAR CE Requirements

IARs are required to complete 12 hours of CE credit per year in order to maintain their IAR registration.  This includes 6 hours of Products and Practices and 6 hours of Ethics and Professional Responsibility.  An IAR taking more than 12 credit hours per year is not allowed to carry forward those excess credits into the following year.

Approved IAR CE Course Providers

IARs are required to take NASAA-approved CE courses from approved course providers.  Any vendor, firm, individual, or state may provide CE so long as the provider and course are approved. The list of approved course providers—including Kaplan—can be found here.

IAR CE Costs

NASAA has implemented a course reporting fee of $3 per credit hour.  Therefore in addition to any training costs, an IAR can expect to pay $36 per year to meet their CE requirement.