NASAA's IAR CE rule: obligation follows the rep

NASAA's continuing-education requirement for investment adviser representatives reads like a simple checklist: six credits of ethics and professional responsibility, six of products and practice. The complexity sits underneath, in a registration map: the membership adopted the model rule on Nov. 30, 2020, and the obligation runs to the IAR's own registration. Anyone registered with an adopting jurisdiction owes CE, whether they work for a state-registered or a federal covered adviser, regardless of where the rep lives or the firm files.

Credit selection is where the program gives ground, since reps can take any approved course that fits their practice from any approved provider, with the public catalog making both searchable. The menu is meant to suit the business model; an employer that wants one consistent curriculum can issue its own internal guidance, but absent that instruction, individual choice controls.

The operational trap is carryover: an IAR who was registered in a CE state for any part of the year keeps the requirement after withdrawing from the state, and a later registration in another CE state may bring that obligation forward. NASAA's FAQ treats the requirement as permanent once it attaches, making CE a per-rep recordkeeping exercise rather than a one-time firm-level signoff.

This publication has made the point before: state oversight follows the rep, and the CE model is that principle applied to training. Practice leaders should pull the registration list and identify every rep who has been registered in an in-scope state for any part of a year. A federal covered registration is no shelter for an IAR individually registered in a jurisdiction that adopted the rule, and the requirement travels with the person. The same logic should shape hiring: a candidate who was registered in an in-scope state is not a blank slate unless the record says otherwise. The 12 credits are the easy half; the harder one is keeping a file that survives a rep's move out of state, because the obligation does not close when the state does.