Michigan Adopts New Continuing Education Requirements for IARs
The Joot blog previously wrote about the Maryland Securities Division’s adopted amendments to its Investment Adviser Regulations. These amendments became effective on December 27, 2021, and, as of this year, investment adviser representatives (IARs) registered in Maryland are required to comply.
Other states are following suit. In keeping with the North American Securities Administrators Association (NASAA), the Michigan Securities Division has also developed specific continuing education (CE) requirements for state-registered and SEC-registered investment advisers. Starting in 2023, IARs must earn 12 CE credits annually to maintain their IAR registration in Michigan. As in Maryland, the 12 CE credits earned in Michigan must be divided equally between two modules:
- Products and Practices
- Ethics and Professional Responsibility
Although the courses IARs are required to take must be approved by the IAR CE program, IARs are encouraged to self-select courses that interest them and that align with their business model. The Michigan Securities Division has provided additional guidance to help IARs understand and meet these new mandatory CE requirements. This guidance addresses the rationale for the requirements as well as unique circumstances for dual registrants and others. While the Securities Division makes clear there are no exemptions or waivers for IARs registered in Michigan, the provided guidance outlines steps IARs should take to resolve any CE deficiencies.
Other states have adopted similar requirements. We can help you determine which states are applicable and how to comply with these new regulations.
Please get in touch if you need help meeting regulatory obligations or filing new forms. Joot’s compliance experts have completed numerous required filings for our clients, and we’re here to help you get compliance done right.