Quick Answer
The Regulatory Element is FINRA-set continuing education completed annually by December 31 for each registration category held, delivered through the FinPro system. The Firm Element is a firm-designed written training plan, evaluated and updated at least annually, that covers a firm's registered persons and its specific business risks.
Once a person is registered, CE keeps the registration current. The Series 24 tests two programs: Regulatory Element timing and Firm Element design.
Regulatory Element
The Regulatory Element is FINRA-set CE content delivered through the FinPro online system. Key features:
- Each registered person must complete the Regulatory Element annually by December 31 for each registration category held
- For a first registration, the standard first deadline is December 31 of the following calendar year. A person first registered in March 2026 must complete it by December 31, 2027
- Content is set by FINRA and the CE Council
- Topics for the upcoming year are published by October 1
- Failure to complete by year-end results in CE Inactive status, meaning the person cannot perform any activity requiring registration until CE is completed
- Applies to permissively-registered persons under the permissive-registration provision as well
| Element | Detail |
|---|---|
| Annual deadline | December 31 each year |
| Coverage | Each registration category held (Series 7 plus Series 24 means two annual completions) |
| Schedule publication | Topics announced by October 1 for the following year |
| Failure consequence | CE Inactive status - person cannot do registered-rep work |
| Permissive registrations | Subject to Regulatory Element |
Exam Tip: Gotchas
- CE Inactive does not terminate registration. A person on CE Inactive remains an associated person subject to FINRA jurisdiction; they simply cannot transact securities business until they complete the overdue Regulatory Element.
- Each category held is a separate annual completion. A Series 24 principal who also holds the Series 7 owes two Regulatory Element completions per year, not one.
Firm Element
The Firm Element is firm-designed CE that supplements the Regulatory Element. Each member must develop and administer a written training plan:
- Covers all registered persons
- Evaluated and updated at least annually
- Plan must address:
- Size, structure, and scope of the firm's business
- Regulatory developments and the topics covered in the prior year's Regulatory Element
Two adjacent training programs may count toward Firm Element:
- Training relating to the anti-money-laundering (AML) compliance program
- The annual compliance meeting
Documentation: Firm Element materials and completion records are subject to the broker-dealer record retention requirement.
Think of it this way: The Regulatory Element is FINRA's standardized content; the Firm Element is the firm's own curriculum tailored to its specific business. A firm that runs a complex options book will design Firm Element training around options supervision; a mutual-fund-only firm will focus on suitability and Reg BI. Both elements run in parallel each year.
Exam Tip: Gotchas
- The Firm Element written plan must be evaluated and updated annually. A plan that has not been revisited in 18 months is a Firm Element violation, even if the underlying training topics have not changed.
- AML training and the annual compliance meeting can count toward Firm Element. They do not create the obligation; they help satisfy it.
Related Compliance Provisions
A handful of adjacent rules round out the registration-system compliance picture:
- Member Filing and Contact Information Requirements: Members must designate and maintain a primary contact for FINRA via the Firm Gateway
- Effect of Suspension or Bar: A member may not associate with a barred or suspended person in any capacity inconsistent with the sanction (including clerical or ministerial).
- It may not pay the person salary, commissions, or other remuneration accruing during the sanction period.
- Narrow exceptions cover insurance or medical plan payments, legal-fee indemnity, an arbitration award or court judgment, and pay shown to have accrued before the sanction that is unrelated to the misconduct.
- Misleading Information as to Membership or Registration: Prohibits filing false or misleading registration information; ongoing duty to correct
Exam Tip: Gotchas
- The no-pay rule for barred persons is broad. A barred rep cannot collect any commission accruing during the bar (even from existing book-of-business trail commissions) if the activity giving rise to those commissions occurred after the bar took effect.
- A misleading-registration-information violation attaches to both the firm and the individual. Filing a false Form U4, ignoring an amendment obligation, or misrepresenting registration status all trigger the rule, and the duty to correct is ongoing.
What Should You Check on Exam Day?
- Do you know the Regulatory Element is due annually by December 31 for each registration category held?
- Can you distinguish the FINRA-set Regulatory Element from the firm-designed Firm Element, which needs a written plan updated at least annually?