MSRB Rule G-3 requires municipal securities dealers and municipal advisors to establish continuing education program requirements.
Dealer Continuing Education
The continuing education (CE) program for dealers is composed of two annual separate components, the Regulatory Element and the Firm Element.
Regulatory Element
- As of January 1, 2023, registered persons are required to complete Regulatory Element on an annual basis. Registered persons now receive content tailored specifically to each representative or principal registration category that they hold. Individuals who fail to complete their Regulatory Element within the prescribed annual deadline of Dec. 31 will be automatically designated as CE inactive.
- Regulatory Element consists of computer-based training on regulatory, compliance, ethical and professional responsibility, and sales practice standards that covered persons are required to participate in and complete by December 31 of every calendar year for as long as they remain an associated person of a dealer or employed by a financial services industry affiliate of a member. Read more about the Regulatory Element requirements for covered persons in Rule G-3(i).
Firm Element
The Firm Element is a firm-administered training program that requires dealers to annually evaluate and prioritize their training needs by conducting a need analysis that takes into consideration the dealer’s size, organizational structure, and scope of business activities, as well as regulatory developments and the performance of covered registered persons in the Regulatory Element. Dealers must also develop a written training plan, based on the needs analysis conducted, and deliver such training annually to its covered registered persons. Read more about the Firm Element.
In addition, the Securities Industry/Regulatory Council on Continuing Education website also provides information about continuing education program requirements that firms may find helpful.
Maintaining Qualification Through Continuing Education
Pursuant to Rule G-3 (i) C) Continuing Education Program for Persons Maintaining Their Qualification Following the Termination of a Registration Category -
Eligible individuals who terminate any of their representative or principal registrations may maintain their qualifications for certain terminated registrations for a period of five years by completing annual continuing education (CE). Eligibility and conditions are outlined in the rule. Similarly, FINRA has established the Maintaining Qualifications Program (MQP). This program provides individuals a maximum of five years in which to reregister with a member firm without having to requalify by examination or having to obtain an examination waiver.
FINRA administers the Maintaining Qualifications Program - individuals should review FINRA’s webpage on The Maintaining Qualifications Program (MQP) for additional information.
Municipal Advisor Continuing Education
The continuing education (CE) program for municipal advisors is required on an annual basis.
- Municipal advisors are required to have a firm-administered training program that requires the firm to annually evaluate and prioritize their training needs by conducting a needs analysis that takes into consideration the municipal advisor’s size, organizational structure and scope of municipal advisory activities, as well as regulatory developments.
- Municipal advisors must also develop a written training plan, based on the needs analysis conducted, plus the requirement to include training on the applicable regulatory requirements and fiduciary duty obligations owed to municipal entity clients, and deliver training annually to its covered persons.
Below are compliance resources that support municipal advisors’ understanding of their continuing education requirements.
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