FINRA Rule 1240.03: Opt-In Senior Leader CE Runs Through Your CCO

FINRA Lets Broker-Dealers Opt Senior Leaders Into Tailored Continuing Education

FINRA has filed Rule 1240.03 as an immediately effective rule change, creating a voluntary Senior Leader Regulatory Element Interim Program that lets member firms have their senior leaders satisfy Regulatory Element continuing education through FINRA-built content tied to senior leader roles. The SEC's Federal Register notice was published on November 5, 2026, as Document No. 2026-22561 at 91 FR 69897, under File No. SR-FINRA-2026-023 and Release No. 34-106797.

Under the rule text, participation is documented by the senior leader's own certification and a representation to FINRA from the firm's Rule 3130 chief compliance officer. For firms that opt in, the compliance burden does not disappear. It moves inside the firm.

That means a decision to opt in is a decision about who signs, what gets retained, and what an examiner could ask to see.

What the Filing Actually Does and When

The SEC's notice is styled as a Notice of Filing and Immediate Effectiveness, so the rule change is already in effect. The SEC filing page lists an issue date of November 2, 2026, and a public comment deadline of November 27, 2026.

Under Exhibit 5, the Interim Program runs from November 2, 2026, through December 31, 2028. The filing also amends Rule 1240(a)(6) to delete the word "technological," so the Regulatory Element may be administered through Web-based delivery or such other manner and format as specified by FINRA.

Who counts as a senior leader

• Any covered person listed on the firm's Schedule A of Form BD.
• Any covered person serving on the firm's executive, management or operations committees.
• Covered persons with similar status or functions employed at an affiliate of the member.

Senior leaders who do not participate remain subject to the standard Regulatory Element requirement under Rule 1240.

The Distinction That Matters: Standard Training Versus Certified Training

The Interim Program adds a documentation layer of its own. The Interim Program is different in kind. Exhibit 5 states that the Rule 3130 CCO "shall provide FINRA with the list of participating senior leaders and represent to FINRA that the senior leaders completed the Regulatory Element material," and that each participant "shall certify" completion while "the member shall retain such certification."

That is a broker-dealer compliance control, not a training perk. If a listed executive did not finish the material, both the executive's certification and the CCO's representation to FINRA would be inaccurate.

The practical consequence is records exposure. A certification the firm would have to retain is a document an examiner could request. Firms that opt in without a defined retention process would be creating a gap they did not have under the standard Regulatory Element process.

Where This Came From and What It Signals

FINRA's June 2026 Board report describes rule proposals approved under the FINRA Forward modernization initiative, including "tailoring continuing education requirements." The June report describes the CE proposal as responding to Regulatory Notice 25-07 and as offering a new voluntary pilot for CE delivery to senior leaders.

The June CE proposal also addressed workload for individuals with multiple registrations, firm training program development, and timing flexibility for CE deadlines. Exhibit 5 to this filing adds only Rule 1240.03 and the Rule 1240(a)(6) delivery change, so this filing does not adopt those other changes.

FINRA Board Chair Scott Curtis said the proposals are "reducing unnecessary regulatory burdens and costs." In this filing, that relief comes paired with a firm-level attestation. Tailoring arrives with a signature attached.