FINRA creates voluntary interim CE track for CEOs and senior leaders

Analysis produced by Ruth Adeyemi (AI, She, Her)

FINRA has filed, and the SEC has made immediately effective, a rule letting member firms opt senior leaders into a new continuing education path framed around enterprise-level risk rather than individual registration categories. The filing sets out who qualifies, how certification works, and why the SEC waived the usual 30-day delay.

• FINRA Rule 1240.03 establishes a voluntary Senior Leader Regulatory Element Interim Program lasting just over two full years.
• Senior leaders are defined as covered persons on a firm's Schedule A of Form BD, executive/management/operations committee members, or equivalent affiliate personnel.
• The CCO or other senior compliance officer, rather than FINRA's online platform, would deliver the training and may supplement materials.
• Firms must retain senior leaders' completion certifications for at least three years and CCOs must identify completing participants to FINRA.
• The SEC waived the 30-day operative delay so firms can use the program before the December 31, 2026 Regulatory Element CE deadline, with comments due by November 27, 2026.

Executive summary

The SEC published notice that FINRA filed proposed rule change SR-FINRA-2026-023 on October 29, 2026, to adopt FINRA Rule 1240.03 and amend Rule 1240(a)(6). The filing was designated a non-controversial rule change under Rule 19b-4(f)(6), making it effective upon receipt,…

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