On December 7, 2021, the Maryland Securities Division announced its new investment adviser representative continuing education requirement, joining Mississippi and Vermont to now require investment adviser representatives to complete investment adviser representative continuing education (“IAR CE”). Closely tracking the NASAA’s Model IAR CE Rule and effective for the 2022 calendar year, investment adviser representatives who are registered in Maryland must now complete twelve credit hours of IAR CE on an annual basis. Of those twelve credit hours, six must be completed in “Products and Practices” and six in “Ethics and Professional Responsibilities,” with at least three focusing specifically on ethics.
As with Mississippi and Vermont’s recently adopted IAR CE rules, Maryland’s requirement applies to investment adviser representatives of both state and SEC-registered investment adviser firms. To the extent an investment adviser representative’s home state doesn’t have a IAR CE requirement, but the IAR is registered in Maryland, then the out-of-state IAR will need to meet Maryland’s IAR CE requirement. If the home state of an out-of-state IAR has not yet adopted an IAR CE requirement and the IAR is registered in multiple states with various IAR CE requirements, Maryland will consider the IAR in compliance if the IAR has satisfied the CE requirements of at least one state that has CE requirements that are at least as stringent as the NASAA model rule.
In addition to adopting an IAR CE requirement, the Maryland Division of Securities no longer provides an exemption from investment adviser representative registration for persons providing investment advice on behalf of state-registered sole proprietors or sole proprietor equivalents. As a result, an individual associated with a sole proprietor, state-registered investment adviser firm in Maryland must now register as an investment adviser representative and comply with Maryland’s IAR CE rule. For further information, Maryland has published a Compliance Guide for its new IAR CE rule.
As state securities regulators continue to adopt the IAR CE Model Rule, NASAA will update its list of member states that are adopting the Model Rule. Currently, Wisconsin, Nevada, and Michigan have each indicated that they are planning to implement an IAR CE rule.
For more information on the IAR CE requirements and adoption by state securities regulators, visit our IAR Continuing Education – Frequently Asked Questions. RIA Compliance Consultants, Inc. is excited to be an approved IAR CE provider and will be announcing our course catalog (subject to approval by Prometric) in the coming weeks.
NASAA does not endorse any particular provider of CE courses. The content of any course offered by RIA Compliance Consultants, Inc. and any views expressed therein are our own and do not necessarily reflect the views of NASAA or any of its member jurisdictions.
If your state registered or SEC registered investment adviser firm is an existing client of RIA Compliance Consultants and has questions about IAR continuing education, we encourage you to speak with your compliance consultant. Or, if you are not an existing client of RIA Compliance Consultants, click here to set up an introductory call with our Business Development Team.
Related Posts & Resources
- Vermont Adopts IAR Continuing Education Rule – December 10, 2021
- Maryland Division of Securities Proposes New IAR CE Requirement – November 03, 2021
- RIA Compliance Consultants Approved as IAR CE Provider – October 26, 2021
- Mississippi Adopts IAR Continuing Education Rule – July 29, 2021
- NASAA Publishes Handbook for Prospective IAR CE Content Providers – May 14, 2021
- IAR Continuing Education – Frequently Asked Questions
- IAR CE – Tracking Spreadsheets – March 22, 2021
- NASAA Investment Adviser Representatives Continuing Education Model Rule Moves Closer to Implementation – January 26, 2021
- NASAA Seeks Input on Investment Adviser Representative Continuing Education Program – September 5, 2020
- NASAA Proposed Investment Adviser Representative Continuing Education Rule – May 11, 2020
The information contained in this blog post is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic. It is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s rules and published guidance for more details about the topics referenced above. For more information about the limitations of this blog post and information on our website, please see our Disclosures webpage.