Senior Leader Regulatory Element Interim Program | FINRA.org

Senior Leader Regulatory Element Interim Program

FINRA is offering member firms an optional path for their senior leaders to satisfy their annual Regulatory Element Continuing Education (CE) requirement. The Senior Leader Regulatory Element Interim Program provides training content developed by FINRA specifically from the vantage point of a senior leader within a member firm. Participation is voluntary, and firms may decide whether any of their eligible senior leaders will participate. The information below is intended to help firms make that determination.

Background

FINRA has established the Senior Leader Regulatory Element Interim Program (“Interim Program”). Under the Interim Program, firms may elect to have eligible senior leaders complete firm-administered Regulatory Element training that is tailored to their unique organizational vantage point in place of the standard Regulatory Element content.  The program is being offered on an interim basis (from November 2, 2026, to December 31, 2028) while FINRA evaluates whether it should be implemented over the long term. Participation is flexible: an individual or firm may participate one year and choose not to participate the following year. For complete details, including eligibility criteria and program requirements, please review the following: SR-FINRA-2026-023: Proposed Rule Change to Adopt FINRA Rule 1240.03 (Senior Leader Regulatory Element Interim Program) to Establish an Interim Program of Regulatory Element Continuing Education

Eligibility

Only senior leaders are eligible to participate in the program. For purposes of the program, a senior leader includes any "covered person," as defined in Rule 1240(a)(5) (Definition of Covered Person), who is:

  • listed on a member firm's Schedule A of Form BD;
  • serving on a member firm's executive, management, or operations committees; or
  • employed at an affiliate of a member firm and has similar status or functions.

Requesting Training Materials

Firms that elect to have one or more senior leaders participate in the Interim Program should submit a request through the webform. Once the request is reviewed, FINRA will provide the firm with the training materials needed to administer the training to its participating senior leaders.

Completion, Certification and Reporting

After a senior leader successfully completes the training, firms should complete the following steps:

  • Senior Leader Interim Program Certification: The firm is responsible for obtaining a certification from the senior leader certifying that he or she has completed the training and retaining the certification for at least three years.
  • CCO notification: The firm's Chief Compliance Officer (CCO) must notify FINRA of each individual who has successfully completed the training so that FINRA can update the individual's CE record accordingly.

Processing time: Once FINRA receives the reported completion information, please allow up to five business days for FINRA to process the information and update the individual's record in FINRA systems. 

If you have questions regarding the program, please contact [email protected].