Annual Training Considerations for Broker/Dealers

It’s 2020 and as the new year rolls in, so does annual training planning. Rule 3110(a)(7) requires each Registered Person to participate, at least annually, in an interview or meeting which discusses compliance matters relevant to their activities. The goal is to discuss compliance issues to remain current on applicable regulatory developments and/or implement changes in Firm policies. Your Firm’s training program is not only a regulatory requirement. Building an effective training program also protects the Firm against litigation risk.

The Firm’s annual training, however, is only one part of the complete picture for training. Many Firms miss key opportunities to add to the Firm’s annual training program. Below is a list of key areas that are often missed in annual training considerations.

Out of Office Training

It is surprising how many Firms have Associated Persons attend conferences throughout the year which are not documented in the training file. A Firm’s overall documentation of training should include any training conducted through product meetings, business conferences, compliance conferences, and other educational opportunities. FINRA’s website provides information on all upcoming conferences and events.

Regulatory License Exams and Continuing Education

If Associated Persons completed required continuing education training, ensure it is included in the training file. Regulatory license exams contain a breadth of knowledge, and firms should not overlook this while building the annual training file. Learn more about the FINRA requirements for Continuing Education.

Company Meetings

Firms often have internal meetings that are a great source to deliver training throughout the year. Firms that conduct daily, weekly or quarterly company meetings can add a few compliance reminders and educational topics. With the inclusion of a sign-in sheet and an agenda, Firms have the opportunity to document substantial training through this method.

In summary, the understanding that training programs can be created through a collaboration of various training opportunities can set a Firm up for a successful year.

Please contact us to learn more about our expert consulting in this area.

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