Second chance for unregistered SAs through the FINRA Maintaining Qualifications Program
FINRA has given SAs deregistered before March 2022 a second chance to maintain their registrations.
Its new Maintaining Qualifications Program (MQP) set up in 2022 enables SAs without an employer to maintain their registration for five years by carrying out continuing education through the FINRA website.
However, SAs deregistered before March 2022 had just two months between January and March 2022 to sign up to the MQP. Some SAs without registrations were unaware of the programme and so failed to get registered, thus risking losing their licence.
FINRA has now opened up a second and longer enrollment period. SAs deregistered between 15 March 2020 and 15 March 2022 now have until 31 December 2023 to register with the MQP. They must have been registered continuously for the 12 months before their registration was terminated. For example, if their registration was terminated on 31 January 2022, they would have to have been registered at the latest on 1 February 2021.
To see if you are eligible for the MQP, log into your finpro account at https://finpro.finra.org/. If you are eligible, there should be a blue box just above the Current Registrations section saying “You may be eligible for the Maintaining Qualifications Program”.
Background: the big bugbear for SAs – 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.
- FINRA Information Notice detailing new enrolment period: https://www.finra.org/rules-guidance/notices/information-notice-031523
- For more details on the MQP see https://www.finra.org/registration-exams-ce/continuing-education/CE-transformation/mqp
- FINRA rule 1240.01 detailing MQP: https://www.finra.org/rules-guidance/rulebooks/finra-rules/1240
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