Meet Your IAR CE Requirements
Complete NASAA’s new investment adviser CE model rule requirements with our top-of-the-line training courses.
➤ B.E.S.T. IAR Courses
Browse our online CE course catalog to select from various course topics that will assist you in fulfilling your IAR CE credit requirements. Upon completion, we will report your credit hour(s) to FINRA within two (2) business days.
➤ IAR CE Requirement FAQs
New requirements can be complicated to understand, but we are here to help. Below are a few common FAQs: (Click on a FAQ’s question to view its answer.) Click here for a complete list of FAQs from NASAA.
A common misconception is that the requirement is triggered by where the IAR firm is registered or notice filed. However, the requirement is applied based on where the IAR is registered regardless of where the IAR is domiciled or the firm is registered or notice filed.
Please note, the credits must be split this way. If an IAR takes 8 credits of Products and Practice and 4 credits of Ethics and Professional Responsibility, they will not satisfy that year’s requirements even though they attained 12 total credits.
An IAR who is dually registered as a broker-dealer agent may report their completed FINRA Regulatory Element CE to satisfy six credits of the Products and Practice component.
Every Ethics and Professional Responsibility course must ensure that at least one-half (50%) of the material in the course is related to an IAR’s ethical responsibility. Therefore, by taking all 6 credits, the IAR meets the 3 credits of ethics that is required by the Model Rule. This ensures that every IAR can meet the ethics component of the IAR CE model rule. If course providers are unable to certify that content on ethical responsibility is covered or if content reviews determine that content on ethical responsibility is insufficient, those courses will not be approved.
An IAR must satisfy six credits annually of this component.
Example: Joe failed to complete his IAR CE requirement for 2022 by December 31, 2022. Any IAR CE courses he completes in 2023 will be applied to the 2022 deficiency until that requirement is completed. Excess credits in 2023 will not be applied to the 2024 IAR CE requirement.
NASAA Model Regulations State Adoptions
State Adoptions of NASAA Rule on Investment Adviser Representative CE (Model Rule 2002-411(h) or 1956-204(b)(6)-CE).
➤ State Adoption Status
The NASAA Model Rule is being adopted on a state-by-state basis, but states are not required to adopt. However, if your state does not adopt the model rule, you still may be subject to completing CE credits for states where you are registered that have adopted the model rule to stay in compliance.
The map below shows each state that has officially adopted the new rule and those considering adoption. The table to the right of the map, lists each state with its effective date of adoption.
Model Rule Effective Adoption Dates
IAR CE Requirements and Deadlines
• When will emails be sent to FinPro users notifying them they still have an outstanding IAR CE requirement?
September 30th, November 30th, and December 15th.
• Why are the reminders limited to FinPro users?
The Form U4 does not ask the investment adviser representative (IAR) to list their email address. Therefore, NASAA is limited to those that have a FinPro account set up. FinPro is a free tool owned by FINRA and is available to all IARs and broker-dealer agents.
• Will the IA firm the IAR is associated with receive any type of notification regarding their associated IARs?
Yes, IA firms can generate their own reports at any time using IARD. In addition, FINRA, on behalf of NASAA will be emailing firms on October 17, November 21, and December 5 to notify them of their IARs that are at risk of failing to renew for IAR CE purposes. These notices will be sent to the firm contact listed on the firm’s ADV.
• When is the last day to submit course completion rosters for guaranteed 2024 processing?
The CRD system will stop processing rosters on December 26th. All course rosters submitted prior to then will be processed and included in the 2024 renewal process.
• What if a roster is submitted between December 27 – December 31?
Those course rosters will still be accepted by the system but will not be processed until the system comes back up on January 2, 2025.
• If an IAR waits to complete their CE until that downtime, will their 2025 registration be impacted?
It depends. If the IAR is caught up on their requirement with the exception of the 2024 year, and are in a “Required” CE status, then no, they will not systematically lose their registration. Their registration status will change to Approved Pending IAR CE on January 2, 2025. Based on the model rule, this is still an approved registration status. Once the courses process on January 2, their registration will automatically change back to Approved.
However, if the IAR is deficient two years (e.g. 2023 and 2024) and are in a “CE Inactive” CE status on December 26, yes, their registration will fail to renew on January 2. Once the course rosters are processed and the IAR is no longer deficient CE, on January 2, the IAR can submit a new Form U4 and seek registration again.
• How can an IAR verify their IAR CE status?
An IAR can review their status, monitor course completions, and many other things through the Financial Professional Gateway (FinPro).
• If an IAR wants to take one of the free courses hosted by NASAA, what is the last day those will be available for inclusion in 2024 processing?
NASAA courses taken through midnight on December 22 will be submitted for processing prior to the December 26 deadline. Courses taken after December 22 will not be processed until the system comes back online on January 2, 2025.
If you have any additional questions or concerns about the details in the memo, please contact the IAR CE team at IARCE@nasaa.org.