All About NASAA's IAR Examination Validity Extension Program (EVEP)

By WebCE
May 4, 2023
How to Plan a Real Estate Business

The newly adopted NASAA Investment Adviser Representative Examination Validity Extension Program Model Rule (referred to as EVEP and The Rule) is the latest attempt by securities industry regulators to answer the call for greater personal and professional flexibility. The change comes in response to FINRA, the Financial Industry Regulatory Authority, adopting changes to their continuing education requirements with the Maintaining Qualifications Program (MQP). NASAA hopes to align states’ requirements with FINRA’s to consolidate the securities industry’s qualification requirements.  

FINRA’s MQP allows eligible securities professionals to maintain their qualifications for up to five years by meeting annual continuing education requirements. NASAA’s EVEP for IARs is similar—five years of qualification sustained with annual continuing education—and considers those in compliance with FINRA’s MQP to be in compliance with The Rule. View our guide on FINRA’s MQP for more information.  

Below, you’ll find a complete guide to NASAA’s new IAR Examination Validity Extension Program (EVEP).  

Why Did NASAA Change Their Continuing Education Requirements?

NASAA, or the North American Securities Administrators Association, adopted this change in their continuing education requirements to align with FINRA’s MQP and similar broker-dealer agent regulations NASAA adopted in September 2022. This change means investment adviser representatives who exit the securities industry do not have to retest upon re-entry, so long as they remain EVEP-compliant and re-enter the industry within a five-year window.  

In fact, those in compliance with FINRA’s MQP are also considered compliant with NASAA’s EVEP. Unlike FINRA’s MQP, however, states must first adopt NASAA’s EVEP model rule before it becomes effective and IARs in that state can participate.  

“This model rule will align investment adviser representative and broker-dealer agent regulations where adopted and will facilitate greater career flexibility for investment adviser representatives,” said NASAA’s Investment Adviser Representative Continuing Education Committee Chair Linda Cena.  

Each of these moves, by FINRA and now NASAA, are regulators’ attempts to consolidate registration requirements and allow for greater personal and professional flexibility. Maintaining qualifications while not in the industry allows professionals to address life and career pursuits, accounting for absences without requiring requalification upon each re-entry.  

What does NASAA's Examination Validity Extension Program (EVEP) Change?

Under NASAA’s EVEP, eligible investment adviser representatives can now maintain their Series 65 (Uniform Investment Adviser Law Examination) or the investment adviser portion of the Series 66 Exam (Uniform Combined State Law Examination) for up to five years while outside the securities industry. Previously, those who exited the industry lost their qualifications and had to retake their qualification exams prior to re-entry into the industry.  

NASAA requires those enrolled in EVEP to complete annual continuing education each calendar year to keep participants’ security knowledge sharp. This IAR CE, detailed in the following section, allows IARs outside the industry to maintain their industry knowledge as they tend to personal matters or pursue other professional avenues. This change also allows those enrolled in FINRA’s MQP to maintain their IAR qualifications.  

What are the Eligibility and Participation Requirements for NASAA's Examination Validity Extension Program (EVEP)?

Eligible investment adviser representatives enrolled in NASAA’s EVEP can now maintain qualifications while outside the industry for up to five years by meeting continuing education and other requirements, listed below.

The EVEP brings several changes to NASAA’s continuing education requirements, including: 
  • New five year window to maintain qualifications—if all continuing education requirements are met each year. (This five year window begins the first full calendar year of registration.)
  • New IAR CE requirements
  • Annual Continuing Education must be completed by December 31 of each calendar year of eligibility 
NASAA aims for the IAR EVEP to offer more career flexibility and allow those to explore other opportunities while maintaining their qualifications. There are some stipulations each securities professional must meet prior to entering the EVEP—once the EVEP is adopted in your state.  

Who is eligible for NASAA’s IAR EVEP? 
  • IAR who terminated registration must have already taken and passed the Series 65 Exam (Uniform Investment Adviser Law Examination) or the investment adviser portion of the Series 66 Exam (Uniform Combined State Law Examination)
  • Must have been registered for at least one year prior to termination of registration
  • Is not currently subject to a statutory disqualification at the time of termination or at any time during the five-year period after termination 
  • Participate in the EVEP within two years of the effective date of their termination 
  • Not deficient in their continuing education program when their IAR registration becomes ineffective 
  • Maintain eligibility in the EVEP program by meeting all continuing education requirements (detailed in the following section)

What are the EVEP's Continuing Education (CE) Requirements?

IARs enrolled in NASAA’s EVEP must complete 12 credit hours of investment adviser representative continuing education from an approved course provider, like WebCE, by December 31 of each calendar year of eligibility. NASAA defines a “credit” as at least 50 minutes of educational instruction. EVEP offers a five-year eligibility window. If an IAR does not re-enter the industry before the end of the EVEP’s five-year window, even if they remain compliant with EVEP, their qualifications will expire.  

Newly registered IARs must complete their first year’s continuing education requirement at the end of the first full calendar year of registration. January 1 begins the first year. In other words, if a participant registers in September, their first full year begins the following year on January 1. Once January 1 passes, they have until December 31 to complete their first year’s IAR CE.   

NASAA’s Investment Adviser Representative Examination Validity Exclusion Program Requirements are: 
  • Six credit hours of Ethics and Professional Responsibility (at least three credit hours dedicated to Ethics) – reviews issues related to an IAR’s duties and obligations to their clients, such as fiduciary duty
  • Six credit hours of Products and Practice – discusses investment products, strategies, standards, and compliance practices relevant to the investment advisory industry

The MQP’s Regulatory Element may count toward the Products and Practice requirement. Dually registered individuals who have completed the Regulatory Element should confirm whether their broker-dealer has opted-in to the FINRA program to automatically apply the Regulatory Element to their IAR CE requirements. If the broker-dealer is not participating in auto-apply, the IAR must make a request to have their Regulatory Element completion applied to their IAR CE requirements and pay the required fees through their FinPro account. Firm Element training may also count toward IAR CE requirements if the training is approved by NASAA.  

Failure to complete the required continuing education by December 31 will result in a ‘CE Inactive’ status. The ‘CE Inactive’ status serves as a notice to the IAR that, if CE is not completed by year’s end, they will be unable to renew their registration. To catch up on missed CE, NASAA requires completing all past CE from previous years before the current year’s CE can be met and an IAR regains full compliance. If an IAR is CE Inactive for a second year in a row, the IAR is not eligible for IAR registration or renewal, and the qualifications expire. Additionally, NASAA does not allow IARs to carry over any IAR CE credits into a new year if more than 12 hours were earned nor are they permitted to repeat a CE course they previously completed.

NASAA EVEP Model Rule State Adoptions

While NASAA’s EVEP has overlap with FINRA’s MQP, it is up to each state whether to adopt the EVEP. If a state decides to adopt the EVEP, the IAR CE requirement takes effect January 1 of the following calendar year. WebCE will be tracking state adoptions of the EVEP model rule and will continue to track state adoptions of the IAR CE Model Rule.  

Taking Your Investment Adviser Representative Continuing Education

NASAA only accepts IAR CE credit hours through approved vendors, like WebCE.  

From our Investment Adviser Complete CE Package to individual courses on everything from Anti-Money Laundering to Senior Investor Concerns so you can build your own, WebCE offers industry-leading online education to help you meet your investment adviser representative continuing education requirements and stay compliant.  

As an approved CFP Board CE Sponsor, all WebCE’s IAR CE courses may also be eligible to receive CFP certification credit.