July 1, 2021
These proposed changes are a step in the right direction. For many small firms, their business and regulatory concerns tend not to change all that much year to year. And the CFA is not really comparable to any FINRA registrations, so that argument for a similar style of CE seems off base. If the regulatory element can take on a larger role, FINRA should consider allowing firms to set their own schedule of training. A firm who conducts one type of business that hasn't changed in years ought not have to repeat the same needs analysis and training plan and training seminars over and over. Doing so seems not to really benefit anyone, yet examinations seem to devote a disproportionate amount of attention here. FINRA should also consider making the regulatory element the primary, if not sole means by which securities industry personnel are made aware of important rules and issues. FINRA knows each of its members business (each has a unique agreement as I understand it), so FINRA is in a great position to know what those members should be relaying to their employees. This way, rather than taking the chance that some Firms will do a better job than others, everyone would be on equal footing on the topics FINRA thinks matter the most.