News

IAR CE Deadline!

We are writing to inform you about the new Continuing Education (CE) requirements for certain Registered Investment Advisers (RIAs), effective under NASAA’s Model Rule for Investment Adviser Representative (IAR) Continuing Education. These requirements impact RIAs in certain states and are designed to ensure financial professionals remain up-to-date on current regulations and best practices.

Key Points:

  • Rule: NASAA’s Model Rule mandates 12 hours of continuing education annually for IARs.
  • Applies to:
  • State-registered IARs in states that have adopted the NASAA Model Rule.
  • SEC-registered IARs if they are required by their state of registration.
  • RRs Outside RIA Business Activities:  If your registered representatives also operate their own RIA away from the broker-dealer, FINRA Rule 3270, FINRA Rule 3280, and FINRA Rule 3110 require that your firm supervises and ensures compliance with these new CE requirements for dual registrants. Broker-dealers must maintain appropriate oversight of their registered representatives’ external business activities, including independent RIAs, to ensure compliance with these continuing education obligations.

States Where the CE Requirement is Effective:

The requirement is already effective or will become effective in the following states:

  • Effective in 2022: Maryland, Mississippi, Vermont
  • Effective in 2023: Arkansas, Kentucky, Michigan, Oklahoma, Oregon, South Carolina, Washington D.C., Wisconsin
  • Effective in 2024: California, Florida, Hawaii, North Dakota, Nevada, Tennessee, Colorado
  • Effective in 2025: Nebraska, New Jersey, Rhode Island, U.S. Virgin Islands

CE Content Requirements:

  • 12 hours of CE annually:
  • 6 hours focused on Products and Practices.
  • 6 hours focused on Ethics and Professional Responsibility.

Approved Providers and Online Course Availability:

The CE requirements can be fulfilled through NASAA-approved courses, many of which are available online for convenience. Some recommended providers include:

Deadlines:

  • Completion by December 31st annually: IARs must complete the required CE by the end of each calendar year.

Additional Considerations:

  • Failure to meet the CE requirements may result in the inability to renew your registration.
  • IARs who are also registered representatives with FINRA may be able to count some of their FINRA Regulatory Element CE towards the NASAA IAR CE requirement.

Please ensure your firm’s IARs are aware of these requirements and complete the necessary education to remain compliant. Feel free to reach out to us with any questions or for assistance in navigating these new requirements.

SIPC Email Scam – Alert!

In an effort to protect its clients, Thornton & Associates, LLC (TAA) would like to inform you of a recent email fraud scheme targeting broker-dealers regarding SIPC filings. This scheme involves unauthorized correspondence impersonating SIPC officials to solicit responses from recipients.

We have become aware that fraudulent email correspondence has been sent to broker-dealers under the name of Josephine Wang, President of the Securities Investor Protection Corporation (SIPC). This email claims that a SIPC disclosure has been issued to the recipient, urging them to respond directly by replying to the provided email address.

Please be advised that the URL included in these emails, “mail-sipc.com,” is not associated with SIPC. SIPC does not and has never used this URL for communications. Additionally, for the past year, SIPC has corresponded with broker-dealers exclusively through its secure SIPC Portal.

If you receive an email that appears suspicious or includes unfamiliar URLs, we strongly encourage you to reach out to SIPC directly at (202) 371-8300 or access the SIPC Portal at SIPC – Broker-Dealer Portal to confirm any recent correspondence.

TAA is committed to supporting our clients’ security and compliance, and we are here to assist if you have questions regarding this matter. Please remain vigilant and notify us if you encounter any fraudulent communications.

FINRA Adopts Amendments to Rule 3240

Regulatory Notice 24-12

Summary

FINRA has adopted amendments to Rule 3240 (Borrowing From or Lending to Customers) to strengthen the rule’s general prohibition against borrowing and lending arrangements between registered persons and their customers, narrow some existing exceptions to the general prohibition, modernize the “immediate family” definition, and enhance the notice and approval requirements related to permissible arrangements. The amendments will become effective on April 28, 2025.

For more information click here: https://www.finra.org/rules-guidance/notices/24-12

Questions concerning this Notice should be directed to:

  • Ilana Herscovitz Reid, Associate General Counsel, Office of General Counsel, at (202) 728-8268 or by email; or
  • Carrie Jordan, Principal Counsel, Office of General Counsel, at (212) 858-4210 or by email.

FINRA Announces New Conference Schedule

February 3, 2016 : Compliance Outreach for Municipal Advisors: http://www.finra.org/industry/compliance-outreach-program-municipal-advisors

February 11, 2016 : Cyber Security Conference in New York City: http://www.finra.org/industry/2016-finra-cybersecurity-conference

April 6, 2016 : FINRA Diversity Summit in New York City: http://www.finra.org/industry/2015-finra-diversity-summit

May 23-25, 2016 : FINRA – Annual Conference in Washington DC: http://www.finra.org/industry/2016-finra-annual-conference

September 7, 2016 : Fixed Income Conference: http://www.finra.org/industry/2016-fixed-income-conference

November 9-10, 2016 : Small Firm Conference: http://www.finra.org/industry/2016-finra-small-firm-conference

Thornton & Associates, is a full service compliance consulting firm.  For more information about our Compliance, FinOp and AML services please call us at (877) 542-6759 or at www.thorntonandassociates.com