Important Fall Reminders to Review Your Form U4s, 2Bs, and Complete CEs

Before the holiday season, it’s prudent to review several records including Form U4, ADV Part 2B, and ensure all Continuing Education (CE) requirements are up to date.

Form U4

Firms and their representatives must keep their Form U4 current to maintain compliance. Form U4 must be updated within 30 days of any material change affecting the firm or its associated individuals. Material changes may include updates such as a change of address, the addition of a new team member, customer complaints, regulatory inquiries, and more. Failure to update Form U4 in a timely manner can result in regulatory penalties or other disciplinary actions.

Form ADV Part 2B

Form ADV Part 2B serves as a brochure supplement for clients and provides detailed information about key advisory personnel, including client-facing representatives, investment strategists, and individuals with discretionary authority over client portfolios. While SEC-registered advisers are not required to file Form 2B with the SEC, it must be updated promptly to reflect any material changes and be easily accessible upon request. State regulatory requirements for Form 2B may vary, so state-registered investment advisers should review their specific state’s rules to ensure compliance.

Why it Matters

Incomplete or inaccurate filings can bring about regulatory scrutiny and penalties. Updating your Form 2B and U5 is instrumental, as is ensuring that your continuing education credits are complete to avoid potential issues with registration.

Jacko Law Group can assist with reviewing your filing requirements to identify any gaps in compliance, provide guidance on necessary updates, and ensure all CE requirements are fulfilled.

Mid-November Deadline Recommended for IAR CE Credits Submission

The California Department of Financial Protection and Innovation (the “CA DFPI”) has issued an important advisory regarding the continuing education (CE) requirements for Investment Adviser Representatives (“IARs”) registered in the State of California. The agency strongly recommends that all IARs complete and submit their 202 CE credits by mid-November 2025.

Twenty-three (23) other states and U.S. territories with CE requirements are making similar suggestions so you are strongly encouraged to review these requirements.

Why Submit Early?
The CA DFPI recommend submitting CE credits earlier than the official deadline to allow sufficient time for the credits to be properly reported and processed before the FIRNA CRD system shutdown scheduled for December 26, 2025. Those who fail to meet the CE requirements will not be permitted to renew their registration for 2026.

Reporting period / Effective date

• The CE requirement in California became effective May 1, 2024.
• For 2024, the compliance period runs from May 1, 2024 to December 31, 2024.
• Credits earned any time in 2024 will count toward 2024 compliance.

2025 Continuing Education Credits

The bulletin does not specifically address California IAR CE credits for 2025. However, according to the North American Securities Administrators Association website (NASAA),  CE credits must be reflected in the CRD system by the end of each calendar year (December 31) to count towards that year’s CE requirement.

Overview of CE Requirements for California IARs

1. All IARs registered in California must complete 12 CE credits annually to stay compliant.

1. CE Credit Requirements
   • Six (6) credits/hours must focus on Ethics and Professional Responsibility.
   • Six (6) credits/hours must focus on Products and Practices.
   • Credits must be earned through authorized providers to be valid.
2. All CE requirements for both 2024 and 2025 must be submitted before the CRD system shutdown on December 26, 2025, to avoid registration renewal issues.

IAR CE Authorized Providers
To ensure your courses are approved, reference the official list of authorized course content providers available on the NASAA website here:
NASAA Approved IAR CE Providers

For more detailed information about the IAR Continuing Education program and specific requirements, please visit the DFPI’s official page here: Investment Adviser Representative Continuing Education (IAR CE) – DFPI

Note: For more information on IARs registered in other states, or in multiple jurisdictions, please visit Investment Adviser Representative Continuing Education – NASAA

Jacko Law Group is ready to help! If you need assistance with updating regulatory documents, reviewing disclosures or otherwise preparing for end of the year requirements, please contact us.  Our team of experienced securities lawyers are here to assist you with meeting your regulatory and legal compliance requirements. Contact us at: 619.298.2880| [email protected].