Letter from 2018 Council Chair

Over the course of 2018, I have had the pleasure of serving as the Chair of the Securities Industry/Regulatory Council on Continuing Education, what we colloquially refer to as the CE Council. I have also had the opportunity to partner with a diverse group of individuals from firms and regulatory agencies who share my passion for education and training as a cornerstone of efforts to ensure the more than 600,000 securities professionals have the knowledge and skills necessary to help investors and promote the integrity of the U.S. capital markets.
The CE Council focuses our attention on the Securities Industry Continuing Education Program, among other areas. We have been exploring a number of opportunities to improve the efficiency and effectiveness of education in the securities industry. Over the past few years, Council has worked with FINRA and other regulatory agencies as they moved the Regulatory Element course online. As you recall, this step allowed registered individuals to complete the course at their convenience at a location of their choosing instead of being confined to a testing center. Apart from greater convenience to firms and individuals, this step also allowed FINRA to reduce the per session fee and has already saved firms over $20 million.
The accompanying document is the result of a partnership between the regulatory agencies and representatives from the industry to transform the CE Program in an efficient and effective manner, while also including several ideas for enhancing the CE Program further. With the goal of customizing the Program to better meet the needs of firms and registered representatives, some concepts are mature and represent potential changes. Meanwhile, others are more exploratory in nature. Members of the FINRA Continuing Education team, on behalf of Council, have discussed these ideas with a range of industry professionals in numerous focus groups, one-on-one conversations, and during CE Council meetings resulting in some of the ideas found here. Many of these ideas have been strongly shaped by suggestions from the industry.
As you will see, some of the ideas in this document are more speculative or exploratory in nature. These are described in broad terms so as to benefit from your views and feedback. Still other ideas are simple areas of interest where the CE Council wants to understand how the current program is working and identify further opportunities for improvement.
I want to share with you our perspective on a few of the ideas you will find in the document. The first relates to allowing registered personnel to maintain their qualifications while not associated with a firm. Currently, qualifications will expire after two years. The document raises the possibility of allowing previously registered persons to maintain their qualifications beyond the two-year period, assuming certain conditions are met. This program change would permit someone to complete various continuing education requirements each year in order to re-register with a firm without having to retake their examinations.
Another consideration in the document involves changes to the Regulatory Element. Currently, the Regulatory Element is required once every three years and assigns individuals to one of four categories based on registration. The limited amount of customization can result in an individual receiving training on topics that may be outside their area of focus. The document explores aligning one’s registrations with the type of training they receive in the Regulatory Element, thereby customizing the content they receive to make it more applicable. Due to the infrequent delivery of the training, the content provided is also not as timely and therefore potentially less helpful. Continuing education required of professionals in other industries is often conducted on an annual basis. The result is more timely and tailored content. To improve the timeliness of content delivered in the Regulatory Element program, the Regulatory Element would be delivered annually and, importantly, would remain cost neutral. The current $55 fee would be reduced to approximately one-third of this amount. Additionally, the time required to complete the course would also decrease to approximately one-third of the current time required.
Technological advancements by FINRA, such as the launch of the Financial Professional Gateway and enhancements to the Central Registration Depository (CRD), are a few examples of system improvements that will further enhance the efficiency of the CE Program, not to mention a multitude of other areas. FINRA systems will be able to assist firms by automatically delivering notifications to a registered representative when their CE window opens and at varying intervals. Firms will be able to opt in to having the automated notifications, including whether they want to receive copies of the notices and/or summaries of notices provided to those with open CE windows. The notifications alone can result in a significant time savings for firms, particularly for those with numerous registered personnel. Ultimately, these system enhancements can collectively result in greater efficiencies to firms, while improving the CE experience.
Financial professionals play an important role in helping investors meet their financial goals and serve as a trusted resource for millions of Americans. From the country’s aging population looking for guidance to young investors looking to grow and protect their future, financial professionals play an important role on many fronts. Providing more timely education on regulatory matters can result in financial professionals who are better equipped to protect investors.
As the chair of this dynamic group of industry representatives, I am excited to share these ideas with you. This document represents our collective effort to improve the CE Program further and keep pace with changes in the industry. We believe there is an opportunity to improve the program further through customization, timelier delivery of content and we believe your feedback can help us get there. As you review the document, please refer to FINRA Regulatory Notice 18-26 which seeks comments on the information in the document. FINRA will be managing this process on behalf of the CE Council.
Comments must be received by November 5 and must be submitted through one of the following methods:
• Emailing comments to pubcom@finra.org; or
• Mailing comments in hard copy to:
Jennifer Piorko Mitchell
Office of the Corporate Secretary
1735 K Street, NW
Washington, DC 20006-1506
I look forward to hearing your feedback as we work together to transform the CE Program and introduce positive changes which can benefit all of us.
Catherine Makstenieks
Chair, Securities Industry/Regulatory Council on Continuing Education

Learn More About Program Enhancements Under Consideration