FINRA Proposes Extending the MQP CE Window

On April 30, 2024, FINRA proposed amendments its Maintaining Qualifications Program (“MQP”) to reopen the period in which certain participants can complete their prescribed 2022 and 2023 continuing education (“CE”) requirements. FINRA’s MQP permits formerly registered industry personnel to re-register within five years if they satisfy certain CE obligations (whereas before the MQP, the deadline was two years). FINRA filed these changes for “immediate effectiveness” and FINRA has sought a waiver of applicable operative delays under SEC rule filing requirements to enable FINRA to immediately implement the proposed changes.  We expect a formal notice from FINRA imminently.

Under the proposed change, individuals enrolled in the MQP in both 2022 and 2023 who did not complete their 2022 and 2023 CE requirements as of March 31, 2024 will be able to do so between May 22, 2024, and July 1, 2024 to continue their participation in the MQP. Additionally, any individuals who complete their prescribed 2022 and 2023 CE content between March 31, 2024, and May 22, 2024, will be deemed to have completed such content by July 1, 2024, for purposes of the MQP.

FINRA plans to contact all affected individuals and inform them of the new CE completion period. Read our prior client alert for more detail about the MQP and eligibility. Firms should also be aware that prior amendments to FINRA Rule 1240(a) modified the CE schedule to operate an annual basis, requiring registered persons to complete the Regulatory Element of the CE program by December 31.

This informational piece, which may be considered advertising under the ethical rules of certain jurisdictions, is provided on the understanding that it does not constitute the rendering of legal advice or other professional advice by Goodwin or its lawyers. Prior results do not guarantee a similar outcome.