I. Continuing Education – Investment Advisers Representatives (IAR)
- If I am an existing New Jersey-registered IAR (i.e., registered prior to 2025), am I required to take continuing education?
Yes. Effective January 1, 2025, as a condition of renewal, every investment adviser representative registered with New Jersey Bureau of Securities is required to take 12 credits of continuing education annually.
Also, effective January 1, 2025, new applicants for registration who are deficient for their CE from other states that require it
- Do the continuing education requirements apply to newly registered IARs? (OR Do IARs have an annual IAR CE requirement immediately upon registration in an IAR CE state?)
No. Individuals that register for the first time as an IAR do not have an annual New Jersey IAR CE requirement until January 1 of the following year.
For example, after passing the Series 65 exam, an IAR applicant becomes registered with an investment adviser in 2025. The newly registered IAR does not need to begin taking the required CE courses until the following full calendar year (2026) and will need 12 credits before the end of 2026.
Note, new applicants for registration who are deficient for their CE from other states that require it will not be allowed to register in New Jersey until they have completed their required CE.
- How many credits of continuing education do I need to take?
Every registered investment adviser representative must take 12 credits annually of continuing education as follows:
- Six (6) credits of investment adviser representative ethics and professional responsibility, including at least three (3) hours covering the topic of ethics; and
- Six (6) credits of products and practice content.
- What does the Products and Practice component cover?
The Products and Practice component is designed to ensure ongoing knowledge and competency related to investment products, strategies, standards, and compliance practices relevant to the investment advisory industry. An IAR must satisfy six (6) credits annually of this component.
An IAR who is dually registered as a broker-dealer agent may report their completed FINRA Regulatory Element CE to satisfy six (6) credits of the Products and Practice component through their FinPro Account.
- What does the Ethics and Professional Responsibility component cover?
The Ethics and Professional Responsibility component is designed to ensure ongoing knowledge and competency related to an IAR’s duties and obligations to their clients including, but not limited to, issues related to the fiduciary duty owed to each client.
An IAR must satisfy six (6) credits, including at least three (3) credits of ethics, annually, of this component.
- If I take more than 12 credits in one calendar year, may I carry them forward to the next year?
No. You may not carry over excess CE credits from one reporting period to any subsequent reporting period.
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Can I satisfy the continuing education requirement from any provider?
Only courses approved by NASAA are eligible for IAR CE credit. Please see NASAA’s website at https://www.nasaa.org/industry-resources/investment-advisers/investment-adviser-representative-continuing-education/ for authorized IAR CE providers. A course taken for IAR CE credit must be approved as such.
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If I hold a professional designation such as CFP or CFA that requires continuing education, will satisfying those requirements satisfy the Bureau’s IAR continuing education requirement?
Only courses approved by NASAA are eligible for IAR CE credit. Please see NASAA’s website at https://www.nasaa.org/industry-resources/investment-advisers/investment-adviser-representative-continuing-education/ for authorized IAR CE providers. A course taken for IAR CE credit must be approved as such.
An IAR who takes a course to maintain a professional designation that is also approved for purposes of IAR CE will receive IAR CE credit for the professional designation course.
- Does the Bureau’s IAR CE requirements satisfy those for other professional designations?
The Bureau cannot address questions about other entities’ CE requirements; you must reach out directly to those entities about their requirements.
- For IAR's registered in multiple states, will attaining the required New Jersey CE credits apply to all states at once?
The IAR CE requirement is 12 credits in a calendar year, not 12 credits per state. If an IAR is already registered in a state requiring CE, adding additional states (like New Jersey) does not impact or add to the CE requirements.
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If I am a dually-registered IAR and take continuing education credit as an agent, does that satisfy my IAR CE requirements?
An IAR who is also registered as an agent of a FINRA member broker-dealer, and who complies with FINRA’s continuing education requirements, is considered to be in compliance with the Products and Practice requirement.
The IAR, however, must still satisfy the six (6) credits of ethics and professional responsibility, including at least three (3) credits of ethics, annually, of this component.
- Who is responsible for tracking whether IARs are up to date with education? The RIA or the IAR or both? How can the RIA Compliance Officer check an individual’s IAR education status?
The IAR is responsible for complying with and tracking CE requirements.
The firm also has the ability and may choose to monitor through FinPro an IAR’s compliance with CE.
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Is there a way to manage my IAR CE requirements?
Yes. You can view your IAR CE transcript and manage your IAR CE requirement through FINRA’s Financial Professional Gateway (FinPro) account.
FinPro provides individuals (current or former representatives) direct access to resources and tools to manage their securities registration information. Go to https://www.finra.org/registration-exams-ce/finpro to create an account.
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Will I need a separate log-in for FinPro as well as my CRD/IARD access through FINRA?
Yes. You will need separate logins to access FinPro and CRD/IARD.
For more information about creating a FinPro account go to https://www.finra.org/registration-exams-ce/finpro.
- Where can I get more information about the IAR CE credit hour and reporting requirements?
There are additional information and resources available on NASAA’s website at https://www.nasaa.org/industry-resources/investment-advisers/resources/iar-ce-faq/.
II. Exam Extension Programs for Agents and IARs
- I am an agent and participate in FINRA’s MQP (Maintaining Qualifications Program), can I maintain my exam qualifications for up to five years after termination?
Yes. Agents who have left the employment of a broker-dealer may maintain their exam qualification for a period of up to five years, provided that the applicant satisfies the conditions of FINRA Rule 1240(c).
- As an IAR, can I participate in FINRA’s MQP?
No. FINRA’s MQP is for agents (of broker-dealers).
However, as of September 16, 2024, New Jersey registered IARs can participate in a similar program, the NASAA Exam Validity Extension Program (EVEP), that allows eligible individuals the opportunity to extend the validity of certain examinations for a period of up to five years.
- As an IAR, can I maintain my exam qualifications for up to five years after termination?
Yes, if certain conditions are met (see N.J.A.C. 13:47A-4.3(c)). An IAR who completes the required CE and:
- Whose registration has been terminated for two or more years;
- Who previously took and passed the qualifying examination for registration (Series 65; or Securities Industry Essentials Exam (SIE) + Series 7 +Series 66);
- Was registered as an IAR for at least one (1) year immediately prior to termination of registration;
- Who is not subject to a statutory disqualification;
- Who is not subject to a securities regulator order requiring they re-take a qualifying examination; and
- Participates in NASAA’s IAR EVEP program may maintain the examination qualification for registration for a period of five years following termination.
III. Continuing Education - Agents
- Does the Bureau have a continuing education requirement for Agents?
The Bureau does not have any additional continuing education requirements for agents beyond what FINRA requires. Additionally, agents who have left the employment of a broker-dealer and would like to maintain their exam qualification for a period of five years must participate in FINRA’s MQP program and complete annual continuing education requirements.
Agents may want to familiarize themselves with FINRA’s continuing education requirements. (see https://www.finra.org/registration-exams-ce/continuing-education )
IV. Supervision – IAR Chief Compliance Officer
- Can a CFP, CFA, PFS, ChFC, or CIC who was exempt from taking the Series 65, become a CCO without a 65?
Effective September 16, 2024, New Jersey Bureau of Securities requires the IA firm’s designated Chief Compliance Officer to pass the Series 65 exam. This requirement applies regardless if they qualify for registrations based upon a professional designation.
Investment Advisers who are registered with New Jersey and currently employ a CCO with the required exam or its equivalent do no need to require that CCO to test to maintain their current position as Chief Compliance Officer.
Note, however, that if the IA employs a new CCO or should the CCO leave their current employer and wish to become the Chief Compliance Officer of another IA, those individuals will either have to satisfy the exam requirements or their equivalent as set forth in N.J.A.C. 13:47A-4.3(a).
- I have not taken the Series 65 Exam. Will the Bureau accept any other examinations?
The Bureau will accept the examination requirements set forth at N.J.A.C. 13:47A-4.3(a).