FINRA opens a new continuing-education route for broker senior leaders

FINRA has opened a voluntary route for broker-dealer senior leaders to complete their annual Regulatory Element training through their own firm. The programme began on November 2 and runs through December 31, 2028, giving firms an alternative for the current year’s continuing-education cycle.[1]

The change transfers delivery to a chief compliance officer or another senior compliance officer using FINRA-developed material. Its content spans registration categories and considers regulatory developments from the perspective of people responsible for the whole business. Firms can supplement that material to reflect their own circumstances.[3]

That creates a practical choice for compliance teams: the potential benefit is a discussion tailored to senior responsibilities; the accompanying task is to deliver the session and document completion. FINRA says it has no reliable estimate of how many leaders are eligible or will take part, so the launch does not establish the programme’s eventual reach.[3]

Eligibility and the completion record

Rule 1240.03 limits eligibility to covered persons who appear on a member’s Schedule A of Form BD, serve on its executive, management or operations committees, or hold comparable status or functions at an affiliate. A senior job title by itself is insufficient unless the person meets the rule’s definition.[2]

Participating firms request the training materials through FINRA’s webform. After training, the leader must certify completion and the firm must retain that certification for at least three years. The chief compliance officer then reports each successful participant to FINRA. The regulator asks firms to allow up to five business days for the individual’s continuing-education record to update.[1]

Senior leaders outside the programme retain their assigned FINRA courses. The filing requires evidence of proficiency; the SEC waived its usual delay to allow use before the year-end deadline.[3]

The programme changes how the Regulatory Element is satisfied. Rule 1240 separately requires the Firm Element, the firm’s continuing-education programme reflecting its business and training needs. Firms therefore need to keep the two obligations distinct when recording what a senior leader has completed.[2]

Participation can change from one year to the next. Unless extended or made permanent through the required process, the new provision automatically expires at the end of 2028.[1][2]

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