Training Isn't Optional for RIAs — It's Proof of a Living Compliance Program

Training isn't optional for RIAs; it's proof of a living compliance program. But not all training requirements are created equal.

Here's what regulators expect:

• Investment Adviser Representatives (IARs): Since 2022, most states under NASAA's IAR Continuing Education Model Rule require 12 CE credits each year — 6 in Products & Practices, 6 in Ethics & Professional Responsibility. CE compliance is tracked through FINRA's FINPRO system, not the SEC, but applies to nearly all state-registered IARs.

• All Other Staff: Even if they're not registered, employees with access to client information or marketing systems must complete Annual Compliance Training at least once a year. This covers core obligations: ethics, privacy, cybersecurity, AML, and firm policies.

• Beyond the Minimum: Regulators increasingly expect topic-specific sessions, e.g., cybersecurity awareness, marketing rule updates, sanctions, or outsourcing risk. These aren't always mandatory, but they are evidence of culture and supervision.

ICS audits RIA training programs to ensure they meet both regulatory and exam-readiness standards.

ICS advises financial institutions navigating regulatory changes of this type. If your firm needs to assess the impact of this development on your compliance program, contact us to discuss.