What should broker-dealers consider when undertaking their annual Needs Analysis?
A. Each firm is required to analyze and evaluate its training needs in light of the firm’s size, organizational structure, scope of business, types of products and services it offers, as well as regulatory developments and the performance of its registered persons in the Regulatory Element. Particular emphasis should be placed on changes to firm or industry demographics from the prior year. New products, new rules related to firm business and problems the firm has experienced, such as complaints, regulatory or legal actions, are other particularly important considerations. Each firm must then administer its Firm Element continuing education program in accordance with its annual Needs Analysis and written plan, and must maintain records documenting the content of the program and completion of the program by covered persons.
