Jul. 02, 2021
Hi- I agree with FINRA's rationale for more frequent Regulatory Element training ,however, I believe the transition from three years to one year may not be necessary and at the very least should be sequenced in two phases: 1) from three to two years and then 2) two years to one year. I think FINRA should consider a two year period first and see if its objectives are met. For smaller firms like mine, I do believe it will increase the administrative workload and costs, however, I believe the price is worth it to remain compliant. That said, I'm not totally convinced annual Regulatory Element training is required at this time. My suggestion would be to start with every two years and after some period of time (2 - 3 years) reassess the situation. If FINRA's objectives are not being met, change to one year. Regards, Brian A. Egwele Managing Director