On March 15, 2022, FINRA embarked on a new program known as the Maintaining Qualifications Program (MQP) that allows registered persons to maintain their registrations for a period of five years instead of the two years that had been granted previously. This is great news for industry professionals as it gives them the freedom to pursue other responsibilities or interests for a longer period of time. Many professionals continue to work in the industry at firms that cannot carry their licenses, work outside of the industry for a period of time or take a break from work for a variety of reasons.
However, the new program is not without requirements. Most importantly, the impetus is on you as the registered person to choose to participate in the program. Firms do not have any responsibility to inform former employees of the program or its details.
There will be a two-year period from the date your registrations are terminated to sign up for the MQP. This gives some flexibility in case you believe you may re-associate with a firm that will hold your licenses during those two years. To participate in the MQP, you must sign up via your FinPro account before the end of that two-year period.
For each year that you participate in the MQP there will be an annual fee of $100 (total, not per license) and an annual continuing education program that must be completed. If you wait the two years allowed to join the MQP you will still be required to pay the fee and complete the continuing education for each of those years in addition to any years that you continue to participate.
The MQP will be administered through each individual’s FinPro account. It is critical that you set up your own FinPro account and update it with your current contact information so that FINRA can reach you about this program. If you are eligible for the program, you should see a notification on your FinPro homepage.
There are exceptions to eligibility to the program as well as many individual circumstances that could bring up questions about how and when you can participate. For example, you must have been registered in the Terminated Registration category for at least one year immediately prior to termination of that category to participate in the program. FINRA has created a website for the Maintaining Qualifications Program that includes FAQs and contact information for specific questions. One topic that has come up often in the FAQs is about those who are a member of the Financial Services Affiliate Waiver Program (FSAWP). That program is still functioning for current participants, but is now closed to new participants.
Unfortunately, if your registrations were terminated prior to March 15, 2022 and you did not sign up to participate in the MQP by the March 15, 2022 deadline, you are not eligible to join the program now, no exceptions. If you are not eligible to participate in the MQP you can still retain your licenses for the original two-year period before they expire.
What About State Licenses?
FINRA is working with the North American Securities Administrators Association (NASAA) to align validity periods for state administered licenses such as the Series 63, and 66. Currently only FINRA-administered licenses are included in the MQP. NASAA has proposed a model rule to allow participation in FINRA’s MQP, in addition to a new NASAA Exam Validity Extension Program (EVEP) to extend the validity period of the Series 63 and securities portion of the Series 66 to five years. NASAA currently proposes further rulemaking that could include the Series 65 and the Investment Adviser portion of the Series 66 in the validity period extension. Several Investment Adviser advocates have commented in favor of this change and have encouraged NASAA to align as much as possible with FINRA’s MQP time frames.
Oyster Consultants have extensive experience providing compliance support to broker-dealers. Among our many services, we can assist you with your qualification and registration needs.
