Does a firm that is a sole proprietorship have to prepare a Needs Analysis and written training plan, and how detailed does it have to be?
A. Every firm must conduct a Needs Analysis and prepare a written training plan that is reasonable for its size and type of business it conducts or plans to conduct. The Needs Analysis of a sole proprietorship² should contain a brief description of the firm’s products and services and the sole proprietor’s background and industry experience. The Needs Analysis and written training plan should address any pertinent recommendations from the Firm Element Advisory, which is published semi-annually by the Council, and should briefly describe the sole proprietor’s other training plans for the upcoming year. Q. Must a firm make special provisions for employees newly hired from other firms in its Firm Element training? For example, does a covered person hired in September need to receive training already delivered earlier in the year? A. The answer depends on an evaluation of the individual’s experience, training and areas of business relative to what the individual will do at the new firm. It
