January 20, 2025
What happened?
Individuals registered as Independent Adviser Representatives (“IARs”) may be required to complete annual Continuing Education (“CE”) credits. The IAR CE requirement was put forward by the North American Securities Administrators Association (“NASAA”) to close the education gap for IARs who are not otherwise subject to CE requirements (see our prior coverage here). A minority of states and jurisdictions in the U.S. have adopted CE requirements, which consists of 12 credits of course work required each year to maintain registration. IARs looking for a New Year’s resolution could add CE credits to the list depending on where they are registered.
What Jurisdictions Require CE?
IARs must complete annual CE credits for applicable jurisdictions where the individual is registered. Note that the IAR’s registration is different from where a firm is registered, or notice filed. The requirement is applied based on where the individual has IAR registrations regardless of office locations or notice filings of the firm.
Failure to complete your annual CE credits for a jurisdiction by the deadline will change your IAR CE Status. This status is visible in the FINRA Gateway.
What does my IAR CE Status Mean?
Your IAR CE Status is visible on Broker Check and the Investment Adviser Public Disclosure (“IAPD”) website under the tab for “Individual.” NASAA is a great resource to understand each status. Those with “Inactive” or “Fail to Renew” need to take corrective action to make up the required CE.
| IAR CE Status | IAR CE Status Icon | IAR Registration Status | Meaning |
|---|---|---|---|
| Not Required | Not Required | APPROVED | Approved. The individual does not have an IAR CE requirement to fulfill this year. |
| Required | Required | APPROVED | Approved. The individual does not have an IAR CE requirement to fulfill this year. |
| Satisfied | Satisfied | APPROVED | Approved. The individual has satisfied the IAR CE requirement for this year and is currently on their IAR CE obligations. |
| Inactive | CE Inactive | APP_PEND_IARCE | Approved-Pending IAR CE. The individual did not complete their IAR CE requirement for the previous year. The individual must make up the required CE before CE and registration statuses automatically update. |
| Failed to Renew | Failed to Renew | IAR_FTR | IAR CE Failed to Renew. The individual did not complete their IAR CE requirements for the previous two years, causing the individual’s IAR registration(s) for which there is a CE obligation to be administratively terminated. To reactivate the impacted IAR registrations, the individual must make up the required CE or re-qualify by examination and then reapply for registration. |
(chart from https://www.nasaa.org/industry-resources/investment-advisers/resources/iar-ce-faq/ in response to the question “How does an IAR CE Status impact an IAR Registration Status and what does each status mean?”)
An IAR with “Fail to Renew” status will lose their registration, and the state will notify them that they can no longer work as an IAR in the jurisdiction nor can they charge fees for such work to residents of that jurisdiction. IARs registered in Arkansas, Kentucky, Maryland, Michigan, Mississippi, Oklahoma, Oregon, South Carolina, Vermont, Washington, D.C., and Wisconsin could face “Fail to Renew” status because the requirement has been in effect in those jurisdictions for two years or more.
As the chart above illustrates, an IAR with “Fail to Renew” status must make up the required CE credits or re-qualify by examination and then reapply for registration as an IAR. If you have a “Fail to Renew” status and need to be registered as an IAR in the jurisdiction, we recommend making up the required CE courses as soon as possible during the first quarter of the year.
How do I Complete IAR CE Requirements?
To complete CE requirements, an individual must take approved CE courses. NASAA maintains a list of approved providers offering these courses (https://www.nasaa.org/industry-resources/approved-iar-ce-providers/). If you have taken other courses during the year, such as courses to maintain a CFP or CFA designation, these could count for CE credit if they are on the approved provider list. Course providers report course completion to FINRA, and individuals can monitor course submissions by logging into their FinPro account. Follow up with the course provider if you do not see course completions appear in your FinPro account. Additionally, it is a good idea to maintain documentation of attendance until you have confirmed the course completion appears in your account.
With CE requirements becoming effective in Minnesota, Nebraska, New Jersey, Rhode Island, and the U.S. Virgin Islands in 2025, more and more IARs will need to complete CE requirements. IARs should complete courses before year-end to avoid an inactive or failure to renew status.
