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Understanding the IAR CE Requirement

What Investment Adviser Representatives need to know to stay compliant - and what happens if you miss the deadline

Overview

If you're registered as an Investment Adviser Representative (IAR) in a state that has adopted the NASAA model rule, you have an annual Continuing Education requirement. This article breaks down what's required, who it applies to, and how to make sure you're covered before year-end.

The IAR CE Requirement at a Glance

IARs must complete 12 CE credits each year, split evenly between two categories:

  • 6 credits in Products and Practices
  • 6 credits in Ethics and Professional Responsibility

Deadline: December 31st each year

A few important details:

  • The 6/6 split is mandatory. You cannot substitute extra credits in one category to make up for a shortfall in the other — even if your total reaches 12.
  • One credit equals at least 50 minutes of educational instruction.
  • Courses must come from a NASAA-approved vendor.

Who Needs to Comply?

The requirement applies to every IAR registered in a jurisdiction that has adopted the model rule — and this includes IARs at both state-registered and federally (SEC) registered investment adviser firms.

This is a common point of confusion, so it's worth repeating: the requirement is based on where the IAR is registered, not on the firm. Your firm's registration location, notice filing status, and even your own physical location don't determine whether you have a requirement — your individual IAR registration does.

Example: An investment adviser firm is SEC-registered and notice filed in Maryland (an IAR CE state). If an individual at that firm is registered as an IAR in Maryland, that individual has an IAR CE requirement.

Not sure if the IAR CE requirement applies to you? Log into your FinPro account. If an IAR CE status appears in the summary section, you have a requirement. If it's not mentioned, you don't.

What About Dually Registered IARs?

If you're also registered as a Broker-Dealer agent, there's good news: FINRA's Regulatory Element CE can count toward your 6 Products and Practices credits, so you won't have to duplicate efforts.

Keep in mind:

  • This applies only to the Products and Practices portion.
  • You must still complete 6 credits of Ethics and Professional Responsibility.
  • Those Ethics credits must be NASAA-approved IAR CE courses.

Do I Have to Take Specific Courses?

No. The program is designed for flexibility — there are no mandated courses. You're free to choose any approved IAR CE courses that appeal to your interests and align with your business model, as long as you meet the 6/6 credit split and do not repeat courses previously completed. 

What Happens If I Miss the December 31 Deadline?

Missing the deadline has real consequences:

  • Your registration renewal fee is still due.
  • Your status changes to "CE Inactive" in CRD — and this status is publicly visible on the Investment Adviser Public Disclosure (IAPD) site and BrokerCheck.
  • If the requirement remains unfulfilled by year-end, you risk being unable to renew your registration.

Don't wait until December - completing your credits early keeps your registration secure and your public record clean.

Helpful Resources

Quest CE's IAR CE Course Catalog (PDF): https://www.questce.com/docs/iar-ce-course-catalog.pdf