Becoming a registered person has not been an easy or inexpensive process. In 2018, FINRA’s creation of the Securities Industry Essentials (SIE) exam was a significant step in simplifying the process for an individual to demonstrate basic industry knowledge. The SIE is open anyone over age 18 and, most importantly, association with a member firm is not required. Passing the SIE, however, does not qualify an individual for registration with a FINRA member firm or to engage in the securities business. The individual must next pass a qualification exam for a specific type of business (a “Qualifying” or “Top Off” exam). In order to take a Top Off exam, the individual must be associated with a member firm. Most smaller firms cannot afford either the time or the money to hire someone that has only passed the SIE exam. I would propose a new program aimed at increasing access to the industry through the 900 community colleges (CCs) in the United States. There are approximately 2 million full-time and another 3 million part-time students enrolled in CCs. In August 2018 the Aspen Institute wrote: “56 percent of Native American undergraduates attend community college, as do 52 percent of Hispanic undergraduates and 43 percent of Black undergraduates.” CCs would be invited to prepare a series of courses that would prepare students for the SIE exam and one or more of the Qualifying exams. These would be the same exams as are now required but rather than requiring association with a member firm, they would require enrollment at an approved CC. Passing these CC exams alone would not qualify an individual to engage in any securities activities that now require association with a member firm. A CC student that has passed both the SIE and a Qualifying exam would still have to be hired by a member firm prior to engaging in any securities activities. In this way, they would be eligible to engage in productive activities immediately. This is similar to the current requirement for a licensed real estate agent. In most states a real estate agent must work through a licensed real estate broker even though they have a sales license. Allowing the completion of the necessary licenses through a community college would expand the job opportunities available to minorities, particularly among smaller member firms.
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Robert Muh Comment On Regulatory Notice 21-17
Becoming a registered person has not been an easy or inexpensive process. In 2018, FINRA’s creation of the Securities Industry Essentials (SIE) exam was a significant step in simplifying the process for an individual to demonstrate basic industry knowledge. The SIE is open anyone over age 18 and, most importantly, association with a member firm is not required. Passing the SIE, however, does not qualify an individual for registration with a FINRA member firm or to engage in the securities business. The individual must next pass a qualification exam for a specific type of business (a “Qualifying” or “Top Off” exam). In order to take a Top Off exam, the individual must be associated with a member firm. Most smaller firms cannot afford either the time or the money to hire someone that has only passed the SIE exam. I would propose a new program aimed at increasing access to the industry through the 900 community colleges (CCs) in the United States. There are approximately 2 million full-time and another 3 million part-time students enrolled in CCs. In August 2018 the Aspen Institute wrote: “56 percent of Native American undergraduates attend community college, as do 52 percent of Hispanic undergraduates and 43 percent of Black undergraduates.” CCs would be invited to prepare a series of courses that would prepare students for the SIE exam and one or more of the Qualifying exams. These would be the same exams as are now required but rather than requiring association with a member firm, they would require enrollment at an approved CC. Passing these CC exams alone would not qualify an individual to engage in any securities activities that now require association with a member firm. A CC student that has passed both the SIE and a Qualifying exam would still have to be hired by a member firm prior to engaging in any securities activities. In this way, they would be eligible to engage in productive activities immediately. This is similar to the current requirement for a licensed real estate agent. In most states a real estate agent must work through a licensed real estate broker even though they have a sales license. Allowing the completion of the necessary licenses through a community college would expand the job opportunities available to minorities, particularly among smaller member firms.