Compliance on the Charles: Boston Regional Summit

June 14- | The Harvard Club of Boston

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Analyzing Your Firm Element Training Plan-Needs Analysis

Your annual Firm Element training should reflect the unique and diverse nature of your firm and your representatives.  Its objective is to promote high standards of ethical behavior, knowledge, and equitable principles of trade by regularly training your representatives on the products or services that they engage in.

The key component to putting together an effective plan is customization.  Your clients, your business, your representatives, and the industry are dynamic and the RRs training needs to be updated annually to reflect these changes.

How do you start the process of customizing your training and determining what your Reps training needs are?  Analysis.  In fact, FINRA requires that you complete an analysis of the needs of your firm and representatives before you develop your plan.

In order to analyze your training needs, consider the following questions:

  1. Who are your representatives and in what products or services do they actively engage? Some products and areas like variable annuities, municipal securities, AML, and research analysis require annual training that could effectively be satisfied via your firm element selections.
  2. Do you have supervisors that should be assigned specific supervisory training?
  3. Have regulators, industry organizations, or the Company determined that there are issues, products, or best practices that are of specific concern and should be addressed via training?
  4. Have your firm’s demographics changed? For example, do you have newer, less experienced representatives that would benefit from taking extra or different courses than your seasoned professionals?  Has your client base changed?
  5. Have you added new products or services to your offerings which would require additional training?
  6. Has the Company or its associated persons been involved in customer complaints, arbitrations, litigation or other actions? How about regulatory reviews, investigations or other disciplinary actions?  Is training needed to prevent future occurrences of these actions?
  7. Are there new rules, regulations, or Company policies that your representatives should be trained on or offered a refresher course?
  8. Have you received input from management or representatives indicating that there is additional training that they would find beneficial?
  9. What courses were completed by representative’s in the last couple of years? If courses have been repeated over the years, is it time to address new topics?
  10. How will the training be delivered to your representatives? Will internal personnel facilitate the training or will it be provided via an outside vendor?  What training technology and delivery mechanisms are available?

While putting the above information together may seem daunting, it can be accomplished by:

  1. Surveying your representatives to confirm the products or services in which they are engaged to help determine topics they feel receiving additional training on would be beneficial and to obtain information on previous training and their assessment of that training;
  2. Surveying management on issues or topics they believe are important to the firm’s and RRs’ business;
  3. Reviewing industry sources on trends and issues of regulatory focus; and
  4. Reviewing the Firm Element Advisory published by the CE Council.

Pulling together and processing your Needs Analysis results can take some time so be sure to start the process at least a month or two before you put your training plan in place.  Your completed Needs Analysis will make your training plan preparation a snap and will ensure that your training requirements are tailor made to your firm’s and representatives’ needs.

If you have questions regarding the Needs Analysis process, please contact your NCS Regulatory Compliance Consultant. NCS Regulatory Compliance is ready to help.  You can call us at  (800) 800-3204 or email us at info@ncsregcomp.com.

Gail Musco