Comment on NASAA Proposed Investment Adviser Representative Continuing Education Program and Implementing Model Rule

The Financial Planning Coalition submitted a comment letter to the North American Securities Administrators Association (NASAA) in response to its proposed model rule regarding continuing education requirements for investment adviser representatives (IAR CE).  The Coalition expressed appreciation for NASAA’s process and the outreach efforts resulting in the IAR CE proposal, including gathering stakeholder input through meetings, surveys and other tools. The Coalition acknowledged the gap NASAA identified in the continuing education (“CE”) requirements of certain financial service professionals at the state level and recognized that NASAA and other regulators have an interest in addressing that gap.   

However, the Coalition emphasized that the IAR CE program and model rule should recognize and accommodate other CE requirements that investment adviser representatives (“IARs”) already must comply.  Absent such a recognition, the proposal may inadvertently and unnecessarily impose duplicative requirements on certain categories of financial professionals, including CERTIFIED FINANCIAL PLANNERTM (“CFP®”) professionals. Accordingly, the Coalition requests that NASAA include an exemption for CFP® professionals in NASAA’s IAR CE program and model rule. 

Read full letter here.