MEMORANDUM. AML ACM ACS RR Courses OSJ Program NRAPs X X X - - RRs X X X X - OSJs X X X X X

Transcription

1 MEMORANDUM To: All Associated Persons Date: June 11, 2014 From: M Securities Compliance RE: 2014 Continuing Education Program Deadline October 31, 2014 M Financial Plaza 1125 NW Couch Street, Suite 900 Portland, OR Phone: Fax: FINRA requires Broker/Dealers to annually formulate, implement and document internal education programs for its Associated Persons. While M Securities recognizes that Member Firms are focused on running and growing their businesses, it is incumbent on all Registered Representatives (RRs) and Non- Registered Associated Persons (NRAPs) to complete the continuing education requirements in a timely fashion in order to demonstrate compliance with FINRA rules. We have made every attempt to offer a CE Program that is meaningful to your practice and respectful of your time. Some features of the 2014 Continuing Education Program ( CE Program ) include: The deadline to complete all required elements of the CE Program is October 31, All CE requirements are available on your personalized M Securities Dashboard, accessible through the M Securities website. Your username and password are the same as your login information for the M Financial website. Your M Securities Dashboard allows you to track your CE Program completion status. RRs can also use their M Securities Dashboard to view their FINRA Regulatory Element status. Similar to past years, the fee for the 2014 CE Program is $50 per RR and will be billed directly to the Member Firm. There is no separate fee for NRAPs at this time. This year, the program has the following components: 1. Anti-Money Laundering Training (AML) AML Course and Company Page 2. Annual Compliance Meeting (ACM) 3. Annual Compliance Survey (ACS) RR and NRAP 4. RR Courses 5. Office of Supervisory Jurisdiction (OSJ) Supervisory Principal Program AML ACM ACS RR Courses OSJ Program NRAPs X X X - - RRs X X X X - OSJs X X X X X IAR ONLY* X - X - - * If you are not a Registered Representative of M Securities Broker/Dealer, but you are an Investment Advisor Representative of M Securities Registered Investment Adviser, you are required to complete the AML training and Annual Compliance Survey. 1

2 All 2014 Continuing Education requirements are available on the M Securities Dashboard, which is accessible through the M Securities website. A single sign-on feature enables you to access your CE requirements by logging on to the Members Area of the M Financial website and then selecting M Securities. Once you are on the M Securities website, please access your personalized M Securities Dashboard by clicking on the compass icon located on the home page. If you do not currently have access to the Members Area of the M Financial website, you can obtain one on the M Financial website by clicking on New Web Account under the Members Login area and requesting a new account with access to the M Securities area. If you have forgotten your password, you can also reset it by accessing the Members Login area. Anti-Money Laundering (AML) required for all RRs and NRAPs Requirement: Complete AML Training Course and Company Page Each year both Registered and Non-Registered Associated Persons of M Securities are required to complete an Anti-Money Laundering (AML) training program. M Securities has again contracted with LIMRA to satisfy both the Securities and Insurance industry requirements, and all M Financial partner carriers have confirmed that they will accept LIMRA s training program. The program is divided into two sections: the AML course and the Company Page. AML Course Same as in past years, there are two course offerings this year: 1. Base Course Anti-Money Laundering for Insurance Producers Required course for those who have not previously taken a LIMRA AML training course 2. Ramifications of Money Laundering Anti-Money Laundering for Insurance Review A Refresher course required for those who have previously completed the LIMRA Base Course*. *In addition to the required Refresher course, your LIMRA Base Course will be reported on your Dashboard, showing the date you first completed the course. You are only required to take the Refresher course and do not need to click on the link to review the Base Course. Company Page The Company Page has been expanded to include important information on Anti-Money Laundering as it applies to brokerage products. Once you complete the Refresher or Base course, you will need to open the M Securities Company Page in order to review this additional information and receive CE credit for the AML training. 2

3 Annual Compliance Meeting (ACM) Requirement: Attend one Annual Compliance Meeting All Registered Persons serving in any capacity must attend an Annual Compliance Meeting. This year M Securities will again offer the Annual Compliance Meeting on-demand (available by logging on to your M Securities Dashboard). RRs will have the flexibility to view the ACM at their convenience. Additionally, RRs who have attended an Annual Compliance Meeting at the M Marketing Meeting in October 2014 will be given credit for the completion of this requirement. NRAPs are required to review the Annual Compliance Meeting content presented on their Dashboard pages by clicking on the appropriate link in the Compliance Requirements section. RR Courses Who: All Registered Representatives Requirement: Obtain two credits (one course = one credit) Mandatory Course: Correspondence and Complaints Elective Courses: Courses will be displayed on your M Securities Dashboard Registered Persons must obtain a minimum of two credits by completing courses available by logging in to their M Securities Dashboard. All Registered Persons are required to complete two courses: one designated course (shown in the Compliance Requirements section) and one course of their choice (from the list in the Rep Electives section). Courses cover a broad range of subjects and can be accessed 24 hours a day, seven days a week. Credits for Insurance CE are not available in conjunction with M Securities CE; however, the option to complete Insurance CE will continue to be available through RegEd. To access Insurance CE, please visit the M Financial Group Members Area and click on the RegEd icon. Annual Compliance Survey (ACS) Requirement: Complete an annual compliance survey All RRs, serving in any capacity, as well as all NRAPs must complete an annual survey based on their individual job function. The surveys, also, incorporate an annual verification of Access Persons personal reportable holdings. 3

4 OSJ Supervisory Principal Program Who: OSJ Supervisory Principals Requirement: Obtain two OSJ Supervisory credits (one course = one credit) Mandatory Course: Promoting Compliant Sales Practices Elective Courses: Courses will be displayed on your M Securities Dashboard An OSJ Branch Office is defined as any Office at which any one or more of the following activities takes place: (i) final acceptance (approval) of new accounts on behalf of M Securities, (ii) review and endorsement of client orders, or (iii) supervision of the activities of Associated Persons at one or more Branch Offices or Non-Branch Locations. Registered Supervisory Principals of offices designated as OSJ branches must undertake separate training specifically designed for their responsibilities. This requirement is in addition to the RR Courses noted earlier. All OSJ Supervisory Principals will need to complete two OSJ Supervisory Principal courses: one mandatory course (listed in the Supervisor Requirements section) and one course of their choice (select from the list in the Supervisor Electives section). The OSJ Supervisory Principal courses do not satisfy the RR Electives requirement nor do RR Electives satisfy the OSJ Supervisory Principal requirement. CE Completion Reports Who: OSJ Supervisory Principals and Designated Office Staff Available Reports: M Securities 2014 CE Report and FINRA CE Report Member Firm OSJ Supervisory Principals as well as designated office staff can retrieve their firms CE completion reports for both 2014 M Securities Firm Element as well as FINRA Regulatory Element requirements. If your firm would like you to have access to the reports, please Compliance@mfin.com with the request. If you have been granted access, CE reports are available through your M Securities Dashboard: 1. Log in to your Dashboard 2. Click on the Resources tab and select Custom Reports 3. From the drop-down menu, select 2014 CE Report OR FINRA CE Report and click Run Report Both reports can be exported to Excel for sorting and filtering by clicking on the Download Report button (located in the upper right corner). M Securities CE Report The 2014 CE report lists the completion status for all Registered Representatives (RRs) and Non-Registered Associated Persons (NRAPs) in your office(s). N/A = component not required for that individual A blank field = the requirement has not been met A date = the requirement was completed on that date 4

5 FINRA CE Report On the second anniversary of passing a Series 6 or 7 exam and every three years thereafter, FINRA requires all RRs to take a FINRA Regulatory Element exam. The FINRA CE Report lists the current Regulatory Element status for all RRs in your office(s) as well as information about future completion timelines. Session 101 = required exam for Series 7 RRs; Session 106 = required exam for Series 6 RRs; Session 201 = required exam for Series 24 RRs Completion status Satisfied = there is no action required from the RR at this time. The report shows the start date of the upcoming requirement window. Completion status Required = the report will include both the start and end date of the RR s exam window. RRs must complete their FINRA Regulatory Element exam by the end date to avoid becoming inactive. Conclusion The M Securities CE Program is designed to help you fulfill CE requirements by offering flexible scheduling options and a diverse course selection. M Securities encourages all Associated Persons to complete their requirements at their earliest convenience. Registered Persons who do not complete the requirements outlined above by October 31, 2014 may be subject to suspension from all securities activities until such time as the requirements are fulfilled. In addition, fines may be assessed. M Securities is committed to working with you to ensure all requirements are met before the deadline. Tracking and documentation are integral to a successful CE program. Individual CE completion status is accessible via your M Securities Dashboard. Completion reports for all RRs and NRAPs within a firm are also available via the Dashboard. Should you have any questions about the CE Program or would like access to your firm s CE report, please do not hesitate to contact your Portland Associate Principal or the Compliance Team at or Compliance@mfin.com. We appreciate your cooperation and look forward to your participation. 5