In November of 2020, the North American Securities Administrators Association (“NASAA”) adopted a new rule (PDF) that will require Investment Advisor Representatives (“IARs”) to complete 12 credit hours of Continuing Education annually, 6 for IAR Ethics and Professional Responsibility Requirements and 6 for IAR Products and Practice Requirements. This will be the first time IARs have been subject to Continuing Education requirements and as NASAA president Lisa A. Hopkins states, is intended to “promote heightened regulatory compliance while also helping investment adviser representatives better serve their clients by remaining knowledgeable of current regulatory requirements and best practices.”

2022 IAR CE Member Adoption

While this marks the first time that IARs will be subject to CE requirements, it will only apply to IARs registered in states that have adopted the model rule. Currently, there are only 3 states that have adopted the model rule:

  1. Maryland
  2. Mississippi
  3. Vermont

IARs registered in these states will be required to complete the 12 credits by December 31,2022 to maintain their registration in these states.

2023 IAR CE Member Adoption

There are a few states who are adopting the new model rule, but not until January 1s, 2023:

There are also a few states who are adopting the new model rule, but not until January 1s, 2023:

  1. Michigan
  2. Wisconsin

There are also some states that are still in the process of finalizing adoption and plan to implement the model rule starting January 1st, 2023

  1. Arkansas
  2. Kentucky
  3. Nevada
  4. Washington, D.C.

IARs registered in states that have decided to implement the new model rule starting in 2023 will be required to complete the 12 credits by December 31,2023 to maintain their registration in those states.

For the most current list of which states are adopting the new IAR CE rule and when, check out the Member Adoption page on NASAA’s website.

Also, check out our previous blog on this topic, NASAA’s New Rule on IAR CE.

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