Registered brokerage representatives historically had two years from their Form U5 filing date to re-register with another firm before their prior qualifications (examinations) would lapse. This two-year window often led to “parking” of registrations or other moves by industry personnel designed to avoid retaking industry exams.
FINRA sought to relieve these outcomes somewhat by amending Rules 1210 and 1240 governing registration and continuing education (CE) requirements. FINRA Rule 1240(c) implements the Maintaining Qualifications Program (MQP), which provides eligible individuals who terminate any of their representative or principal registrations the option of maintaining their qualifications for up to five years by completing annual CE.
Individuals whose registrations were terminated within two years prior to March 15, 2022 now have until December 31, 2023 to enroll in the MQP. FINRA extended the enrollment window for these “Look-Back Individuals” after learning that many may have been unaware of the MQP or the enrollment deadline due to communication and operational issues. These Look-Back Individuals who elect to participate in the MQP must complete 2022 and 2023 MQP CE content by March 31, 2024 and pay the annual program fee of $100 for 2022 and 2023 when they enroll.
An individual whose registration was terminated on or after March 15, 2022 will still have up to two years to elect to participate in the MQP (the election can be made through the Financial Professional Gateway).
Read our prior client alert for more detail about the MQP and eligibility. Firms should also be aware that amended FINRA Rule 1240(a) transitioned the CE schedule to an annual basis, requiring registered persons to complete the Regulatory Element of the CE program annually by December 31.
Nicholas J. LosurdoPartner