On February 28, 2022, Wisconsin published new rule
Wis. Admin. Code s. DFI−Sec 11, which sets out continuing education (CE) requirements for investment adviser representatives (IARs). These requirements went into effect January 1, 2023, which means Wisconsin registered IARs will begin taking and reporting CE credits in 2023.
This new rule represents the culmination of years of work by the North American Securities Administrators Association (NASAA), its members (state securities regulators), and industry to develop a relevant and responsive IAR continuing education program. This CE program will promote heightened regulatory compliance while also helping investment adviser representatives better serve their clients by remaining knowledgeable of current regulatory requirements and best practices.
To learn more about NASAA and its mission, please visit
nasaa.org.
IAR CE Requirements
IARs will need to attain 12 CE credits each year to maintain their IAR registration. A "credit" is a unit designated by NASAA to be at least 50 minutes of educational instruction. Some courses offer more than one credit depending on the length of the course. Generally, the provider's course description will identify the number of credits available for completing the course.
The 12 credits must include six credits of Products and Practices and six credits of Ethics and Professional Responsibility. The mandatory CE program will apply to all registered IARs of both state-registered and federal covered investment advisers. IARs will self-manage selecting and completing courses, which will enable them to tailor their CE to their interests and business models. Courses are offered by NASAA approved course providers, which can be found on NASAA's website.
Financial Professional Gateway (FinPro)
FINRA’s Financial Professional Gateway (FinPro) provides individuals (current or former representatives) direct access to resources and tools to manage their securities registration information and a platform to monitor their continuing education requirements. FinPro is an important tool for IARs because it provides them with a mechanism to view courses taken and the progress towards completion of their annual CE requirement. Since IARs are responsible for ensuring their CE vendor reports completion of CE, they may find FinPro useful for tracking and monitoring CE.
Features of FinPro:
- Track and monitor CE
- View CRD record
- Schedule an exam
- Review/download last Form U5
An instructional guide to set-up a FinPro account can be accessed on 
FINRA's website.
Additional FinPro questions? See
FinPro’s list of Frequently Asked Questions.
IAR CE Frequently Asked Questions
Who must comply with the IAR CE requirements?
Every IAR registered in Wisconsin must comply with IAR CE requirements. The program applies to all registered IARs of both state-registered and federal covered investment advisers.
When do IARs need to begin complying with the IAR CE requirements?
IARs registered in Wisconsin as of January 1, 2023, must begin taking CE courses in 2023, and obtain the required 12 credits by December 31, 2023.
When an individual registers for the first time as an IAR, they will not be subject to the CE requirements until the next calendar year. Similarly, if an IAR is registered only in states without a CE requirement and becomes registered in a CE state for the first time, that IAR will not need to comply with those CE requirements until the next calendar year. For example, if an IAR has not been registered in any states requiring CE and registers in Wisconsin during 2023, that IAR will begin complying with the CE rules in 2024. However, IARs who are already registered in an IAR CE state prior to registering in Wisconsin must continue to complete their CE credit schedule for that calendar year. See also “What if an IAR is registered in more than one state?” below.
How many credits/hours are required?
Beginning in 2023, IARs will need to obtain 12 CE credits each year to maintain their IAR registration. A "credit" is a unit designated by NASAA to be at least 50 minutes of educational instruction. Some courses offer more than one credit depending on the length of the course. Generally, the provider's course description will identify the number of credits available for completing the course.
The 12 credits must include:
- six credits of Products and Practices and
- six credits of Ethics and Professional Responsibility
Generally speaking, an IAR cannot receive credit more than once for the same course and must take care to avoid duplicate courses in subsequent years. (An exception to this is a course that is updated and receives a new course number.)
Where can IARs find a list of approved course providers?
To obtain credit, courses must be approved for the CE program. A list of approved providers can be found on the
NASAA website.
What if an IAR is registered in more than one state?
An IAR registered in more than one state must comply with the requirements of each state securities regulator. However, per
Wis. Admin. Code s. DFI−Sec 11, an IAR is considered in compliance with Wisconsin’s CE requirements as long as both of the following are met:
- The IAR's home state (where the IAR has their principal office and place of business) has adopted IAR CE requirements that are at least as stringent as Wisconsin’s; and
- The IAR is in compliance with their home state requirements.
If an IAR already maintains CE credits for certain professional designations, can those be used to fulfill Wisconsin’s IAR CE requirements?
Yes, credits from CE courses taken to maintain professional designations can apply to the IAR CE program so long as the provider and course have been approved through Prometric for IAR CE purposes. Providers will likely promote the fact that certain courses qualify for IAR CE so IARs can look for courses that meet the CE requirements for both IAR CE and their professional designations.
For dually registered IARs, can the CE required by FINRA for broker-dealer agents be used to fulfill any of the CE requirements for IARs?
Yes, an IAR who is also a registered broker-dealer agent and who complies with FINRA's CE requirements is considered to be in compliance with the requirement to report six credits of Products and Practices content, so long as the FINRA CE content continues to meet certain baseline criteria as determined by NASAA and payment is made in CRD of a $3 per credit reporting fee. Please note, you must speak with your broker-dealer to determine if they want to report it on your behalf or if you should self-report your completion through FinPro and pay the applicable reporting fee of $18 ($3 per credit hour times six credits). To self-report the completion, you will need to log in to FinPro and scroll to the "Continuing Education" section where you should see a header for IAR CE. Next to your "Incomplete" status, click the "Apply Regulatory Element Credit" link and follow the prompts to pay the reporting fee. Please note, there will be no refunds. In addition, if for any reason your reporting fee payment is not processed or is charged back you will not receive the corresponding IAR CE credits.
What happens if an IAR does not complete the CE requirements in a timely manner?
If an IAR does not complete the CE requirement by the annual deadline, the IAR will pay the registration renewal fee and CRD will set their IAR CE status to "CE Inactive." Current CE status will also appear in the Investment Adviser Public Disclosure (IAPD) and BrokerCheck. The IAR can continue to do business, however, if CE is not completed by the end of the second year, the IAR will be unable to renew their registration and it will be terminated for failing to complete CE.
I terminated my registration in the state requiring IAR CE. Why is the IAR CE still required on my registration?
Termination of an IAR registration from a state requiring CE does not remove the requirement. IAR CE requirements are maintained if an IAR has been registered with a state which requires IAR CE for
any part of the year. The requirement continues to exist and may affect future registrations in IAR CE states.
This is true beyond the current reporting year. The IAR should remain current on their IAR CE requirements to ensure that future state registrations aren't impacted. An IAR CE deficiency will not impact state registrations in states that haven't adopted the rule. However, if that state adopts the requirement in the future, the IAR's registration will be impacted on the rule's effective date if the IAR hasn't maintained the requirement.
How does the IAR CE Status impact an IAR Registration Status and what does each status mean?
IAR CE Status
| IAR CE Registration Status
| Meaning |
IAR CE Not Required
| Approved | The individual does not have an IAR CE requirement to fulfill this year.
|
IAR CE Required
| Approved | The individual has an IAR CE requirement to fulfill this year.
|
IAR CE Satisfied
| Approved | The individual has satisified the IAR CE requirement for this year and is current on their IAR CE obligations.
|
IAR CE Inactive
| Approved-Pending IAR CE
| The individual did not complete their IAR CE requirements for the previous year.
|
IAR CE Fail to Renew
| Terminated-No IAR CE
| 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 registration(s), the individual must make up the required CE or re-qualify by examination
and then reapply for registration.
|
If you have additional questions, please visit NASAA’s
IAR CE webpage or their
full list of frequently asked questions, or call a Division Securities examiner at (608) 266-2139.
Contact Us
Phone: (608) 266-2139
Email: DFISecurities@dfi.wisconsin.gov