The Vermont Department of Financial Regulation (“DFR”) enacted legislation to adopt annual continuing education requirements applicable to both state-registered and federal covered investment adviser representatives. Investment advisers play an important role in their clients’ financial lives and Vermont residents will be further protected by ensuring their financial professional’s level of knowledge and competence is maintained or expanded.
The amended Regulation, entitled the “Vermont Securities Regulations S-2016-01” mandates every investment adviser representative (IAR) to annually complete 12 continuing education (CE) credits to maintain their IAR registration. The 12 credits must include 6 credits of Products and Practices courses and 6 credits of Ethics and Professional Responsibility courses.
The amended Regulation is effective 12-16-2021 and provides for the following:
Compliance will begin with the 2022 calendar year. CE credits must be reported by the end of each year. Newly registered IARs will be required to meet the annual continuing education requirement by the end of the first full calendar year following the year in which they first become registered.
IARs will self-manage finding and completing courses, which will enable them to tailor their CE to their interests and business models. The courses may be offered by various vendors who are required to apply and obtain course approval from Prometric, the designated course manager, who will maintain the approved course list. The IAR is responsible to ensure the vendor reports completion of CE and will utilize FinPro for tracking and monitoring of his or her CE. https://www.finra.org/registration-exams-ce/finpro
CE programs mandated by IARs that are dually registered as agents of broker-dealers and IARs whose professional designations are contingent on the completion of CE will be taken into consideration. The new CE requirements are intended to be compatible with other continuing education programs that seek to ensure its members stay current with industry matters relevant to the services and products offered to their clients.
An IAR who completes continuing education in excess of the credit amount required for the annual reporting period may not carry forward excess credits to a subsequent reporting period.
If an IAR does not complete the CE requirement by the annual deadline, CRD will set his or her IAR registration status to “CE Inactive,” which is the status that will then appear in the Investment Adviser Public Disclosure (IAPD) and in FINRA BrokerCheck. The IAR will remain “CE Inactive” until either becoming compliant or state action is taken. An IAR who is CE inactive at the close of the next calendar year is not eligible for IAR registration or renewal of an IAR registration.
An IAR who was previously registered and becomes unregistered must complete IAR CE for all reporting periods that occurred between the time that the IAR became unregistered and when the person became registered again during the two-year exam window. Alternatively, the IAR would need to complete any missed CE unless the IAR re-takes and passes the Series 65 or Series 66 examination or receives an examination waiver.
A complete copy of the amended Regulation is available at: https://dfr.vermont.gov/reg-bul-ord/vermont-securities-regulations. The IAR CE specific information is located on pages 72-75.
The NASAA IAR CE Resources page contains regularly updated content. It is recommended this page is used as a reference: https://www.nasaa.org/industry-resources/investment-advisers/investment-adviser-representative-continuing-education
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