FINRA eases two-year limit for unregistered SAs

Hugh Farmar

Hugh Farmar

One of the biggest bugbears for SAs is the danger of losing their licence once they are out of work.

From the date of being de-registered by a firm, SAs have two years to get re-registered and keep their licence active.

If they don’t manage this, after the two years are up, they have to retake the Series 16 exam, but they can only do this if they can persuade a firm to take them on and sponsor them to do so.

However, most firms require SAs to have an active licence in place before they will hire them.

This leads to a Catch-22 situation: in order to get re-registered they have to be taken on by a firm, but in order to be taken on by a firm they have to be registered!

Some firms will allow unregistered SAs to retake the exam while working and sometimes it is possible to obtain a waiver from FINRA. But neither option is certain.

This has been a source of unfairness for out-of-work SAs, particularly those who have had the bad luck of losing work during a prolonged downturn.

Change is coming

FINRA has recognised this unfairness and after a long period of consultation has approved a change to the rules effective 15 March 2022.

SAs who have been de-registered will now have five years to secure registration again instead of the current two before their licences become inactive.

To do so, they will have to complete annual continuing education through the new Maintaining Qualifications Program (MQP) available through the website. No sponsorship will be required.

The MQP will be launched on 15 March 2022. MQP content will become available by 1 July 2022.

Unfortunately registrations inactive for more than two years at the start of the programme (i.e. inactive before 15 March 2020) will not be eligible.

For more details on the MQP see