IAR Continuing Education: The Mandatory 6/6 Split and Why FINRA CE Only Covers Half

Investment adviser representatives have a continuing education requirement that most people still describe wrongly. It is 12 credits a year in a mandatory split, it follows the state of registration rather than the firm, it cannot be waived on the strength of experience or qualifications, and — the part that catches dual registrants — FINRA's Regulatory Element covers only half of it.

This guide works through NASAA's IAR Continuing Education programme as set out in its current FAQs, published July 2026. NASAA's membership voted to adopt the model rule on 30 November 2020, and the requirement takes effect in a jurisdiction on 1 January of the calendar year following that jurisdiction's adoption.

Twelve credits, and the split is not negotiable

The annual requirement is 12 CE credits, where a credit is "at least 50 minutes of educational instruction", divided as:

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

NASAA is explicit that the credits "must be split this way", and gives the failure case directly: 8 Products and Practice plus 4 Ethics "will not satisfy that year's requirements". Twelve credits in the wrong proportions is a deficiency, not compliance.

For a course to count as Ethics, "at least one-half (50%) of the material in the course is related to an IAR's ethical responsibility".

All credits must come from NASAA-approved courses from approved providers. One change worth noting for anyone working from older guidance: NASAA's 2025 FAQs attributed course and provider approval to Prometric; the current version says NASAA reviews and approves providers and courses throughout, and the word Prometric no longer appears.

The dual-registrant trap

This is the single most useful thing in the FAQs for a firm with people holding both registrations.

FINRA's Regulatory Element CE can satisfy the 6 Products and Practices credits, "so long as the FINRA CE content continues to meet certain baseline criteria as determined by NASAA". FINRA's Maintaining Qualifications Program CE can also count toward Products and Practices, self-reported through FinPro. FINRA Firm Element training counts "if the training is approved by NASAA".

What the FAQs say about FINRA CE counting toward the Ethics half is nothing at all. Only Products and Practices credit is stated.

So a dual registrant who completes their FINRA obligations has, on the face of these FAQs, covered six of their twelve IAR credits and still owes six Ethics and Professional Responsibility credits. A firm that treats FINRA CE as discharging IAR CE will produce a deficiency in every adopting state its people are registered in. Our guide to FINRA's Regulatory Element and Firm Element under Rule 1240 sets out that side of the obligation.

Where Regulatory Element credits are self-reported through FinPro, the fee is "$18 ($3 per credit hour times six credits)", payable by the firm or the IAR. The general reporting fee is $3 per credit per person, due when the provider submits the roster.

It follows registration, not the firm or the person's address

The requirement applies "based on where the IAR is registered regardless of where the IAR is domiciled or the firm is registered or notice filed".

Three consequences:

• If an IAR's home state has not adopted the rule but another state of registration has, the IAR "must still comply with the CE requirements of each of the other states"
• Where the home state's requirement is "at least as stringent as the model rule" and the IAR meets it, 12 credits a year satisfies both — there is no doubling for multi-state registration
• Adding a CE state part-way through a year brings that year's requirement with it: "the current IAR CE completion requirement will apply to the new state"

A deficiency applies "in all states where the CE rule is effective", and does not affect registrations in states that have not adopted.

Neither NASAA FAQ names or counts the adopting jurisdictions, and neither gives an "as of" date for a list — the position changes, and NASAA maintains a separate member-adoption page. Any guide quoting a fixed number of states is quoting a snapshot.

How credits are earned and tracked

Providers report completions to FINRA, which NASAA uses as its vendor for programme tracking, and "There is no need to directly report the completion of CE to your state securities regulator". The IAR's job is to attend, complete any assessment, and give the provider their CRD number — then check the submission appeared, via FinPro.

Several mechanical rules are worth knowing before buying training:

• Every self-study and on-demand course must carry an assessment, passed "with a score of at least 70% within no more than three attempts"
• Live courses, as of 1 August 2023, must instead offer an opportunity for audience engagement rather than an assessment
• Self-study has no cap — "there is no limitation/maximum credits restriction" — provided the course is approved. That is unusually permissive; most legal CPD schemes cap or exclude it
• Duplicates do not count. Each course must have a unique course identification number, so repeating the same approved course earns nothing the second time
• Teaching earns credit "once for each unique course he or she leads"

Credits from other professional designations count only where "the provider and course have been approved" for IAR CE purposes. And NASAA adds a caveat that matters when a provider advertises designation credit: "NASAA does not independently verify provider claims regarding course approval for professional designations." Verify with the provider.

No carry-forward, and a deficiency doubles the next year

An IAR "may not carry forward excess credits into a subsequent year". Worse, the direction of application is fixed: credits earned in a year "will first apply to the past year if there is a deficiency", then to the current year.

So a 12-credit shortfall does not simply roll over — the following year requires the missing 12 plus that year's 12, and anything completed is consumed by the backlog first.

The deficiency cascade

NASAA sets out a three-stage sequence, and the terminology is specific:

1. Miss the year-end deadline — the IAR pays the registration renewal fee and "CRD will set his or her IAR CE status to 'CE Inactive'". CE Inactive is notice that if CE is not completed by the CRD System Shutdown date — a date FINRA determines each year, not a fixed calendar date — the IAR will be unable to renew
2. A full year's deficiency — status becomes "Approved – Pending IAR CE" in all IAR CE states, and the IAR must make up 12 credits plus the current year's 12
3. Two consecutive years — "your registration failed to renew in all IAR CE states", and the IAR must catch up "before resubmitting your U4"

An IAR who remains CE Inactive at the end of the following year and has not completed by the shutdown date "is not eligible for IAR registration or renewal". Once the requirement is met, the status updates automatically to "Satisfied".

One thing the FAQs do not address: whether a CE Inactive IAR may continue to do business in the meantime. They speak only to renewal and registration eligibility. That is a gap worth taking advice on rather than assuming either way.

There are almost no exemptions

NASAA's answer is blunt: "There are no exemptions or waivers available based on experience or other qualifications." The HTML version of the FAQs adds age to that list.

What exists:

• Newly registered IARs have no coursework requirement until January of the first full calendar year after registration
• Changing firms mid-year does not reset anything — credits completed before the switch still count
• State waivers exist but apply only to the granting state, and "Waivers will usually only be granted under extraordinary circumstances"

What does not exist, in either version of the FAQs: any provision for parental leave, illness, extensions or reductions. Every other scheme covered in this library — Scotland, Australia, Hong Kong, the CLSB — has an absence mechanism. IAR CE, as documented, does not.

And the requirement does not lapse when you step back. NASAA puts it as plainly as it can: "once an IAR has the requirement, they will always have the requirement." Dropping a registration does not end it.

Three things to check

First, whether your dual registrants have six Ethics credits, not just their FINRA Regulatory Element. This is the most likely source of a silent firm-wide deficiency.

Second, whether anyone has 12 credits in the wrong split. Eight and four is a deficiency with a full year's catch-up attached.

Third, that training you are buying is NASAA-approved for IAR CE specifically, with a unique course identifier, rather than approved for a designation and assumed to transfer.

For the examination that precedes all of this, see our guide to the Series 65 investment adviser representative examination. For structured ongoing development against a requirement with no absence provisions and no carry-forward, our CPD programmes are built around planning rather than catching up.

Sources and limits: written from NASAA's IAR Continuing Education FAQs published July 2026, compared against its February 2025 PDF and its web FAQ page, read in October 2026. The NASAA IAR CE Model Rule text, the IAR CE Program Requirements, NASAA's member-adoption list and its IAR CE status chart were not read — so the list of adopting jurisdictions, the current year's CRD System Shutdown Date and the precise mapping of CE status to registration status are not stated here. State-level rules may add requirements. General information about a published programme, not legal or compliance advice.