CAL DFPI IA Continuing Education


On Dec. 2, CAL DFPI proposed IA continuing education requirements.


  • CAL DFPI proposed Continuing education (CE) requirements for investment advisors.
  • Investment advisors and all-natural persons associated with such advisor are required to meet training and experience requirements pursuant to CAL FIN 4-1-3-25236.
  • CE Requirements
  • Required Investment advisor representatives (IARs) to complete CE requirements each reporting period, including 6 credits of ethics and professional responsibility content.
  • Also, 6 credits of IAR products and practice content offered by an authorized provider.
  • IAR who is also registered as an agent of a FINRA member B/D and complies with FINRA's CE requirements is considered to be in compliance with CAL CE requirements.
  • As long as FINRA CE content meets set baseline criteria as determined by NASAA.
  • CE reporting requirements defined; credits may not carry forward to next reporting.
  • An IAR registered in State who is registered as an IAR in home State is considered to be in compliance if home State CE requirements as stringent as NASAA model rule.
  • Further, the IAR must be in compliance with the home IAR State's CE requirements.
  • Unregistered IARs must complete CE for all reporting periods that occurred between the time that the IRA became unregistered and when the IRA was registered again.
  • Any IAR employed by an investment adviser only to offer for the sale of investment advisory services of an investment adviser is not subject to provided CE requirements.
  • Consultation
  • Comments on CE requirements for investment advisors are due by Jan. 16, 2023.
  • Feb. 2024 CAL DFPI Modified Continuing Education Proposal
  • On Feb. 16, 2024, CAL DFPI modified the Dec. 2022 proposal PRO 07/21 on IA CE.
  • CAL DFPI filed proposal with Office of Administrative Law (OAL) on Oct. 24, 2023.
  • On Dec. 8, 2023, OAL disapproved for failure to comply with clarity standard of the Administrative procedure act; Commissioner now proposing changes to regulations.
  • Rulemaking record was updated to include following documents relied upon: NASAA 2021 IA section report; NASAA member survey results; and NASAA IAR CE FAQs.
  • Incorporated by reference pages 7-11 and 20-27 of the NASAA IAR CE Program Handbook, January 2023 Edition; Provided redline version of modified regulation.
  • Comments on the modified CE proposal must be submitted by Mar. 1, 2024.
  • Apr. 2024 CAL DFPI Final Rulemaking Submission
  • On Apr. 4, 2024, CAL DFPI resubmitted IAR CE final rulemaking to the Office of Administrative Law for approval on Mar. 28, 2024, to be effective May or Jun. 2024.
  • Credits earned at any time in 2024 will be accepted, count toward 2024 compliance.
  • May 3, 2024 CAL DFPI Final Adoption
  • On May 3, 2024, CAL DFPI adopted NASAA's adviser representative continuing education model rule as its standard at CAL FIN 10-3-2-260.236.2; effective May 1st.
  • May 6, 2024 CAL DFPI Final Rule
  • On May 6, 2024, CAL DFPI reported that rulemaking file was approved by Office of Administrative Law, and filed with Secretary of State, immediate effect on May 1st.
  • Further, published final text of the regulation, and the final statement of reasons.
  • Oct. 2024 CAL DFPI CE Deadline
  • On Oct. 21, 2024, CAL DFPI reported that each IA with a full year of registration must complete 12 CE credits, completed and reported by course providers by Dec. 26, 2024.

Regulators CAL DFPI
Entity Types B/D; IA
Reference Nt, 10/21/2024; RF, Info, 5/6/2024; PR, RF, Nt, 5/3/2024; PR, 4/4/2024; RF 07/21, 2/16/2024; Nt, RF, 12/2/2022; Citation: *CAL FIN* 4-1-3-25236, 10-3-2-260.236.2;
Functions Compliance; Financial; Legal; Operations; Registration/Licensing; Training
Countries United States of America
Category
State
Products Education; Fund Mgt; Securities
Regions Am
Rule Type Final
Rule Date 12/2/2022
Effective Date 12/26/2024
Rule Id 155285
Linked to N/A
Reg. Last Update 10/21/2024
Report Section US Investment

Last substantive update on 10/26/2024