FINRA’s Maintaining Qualifications Program (MQP) Explained

For independent investment bankers and transaction professionals, career paths are rarely linear. Whether stepping away between deals, launching a new platform, or navigating a transition between firms, maintaining your licenses can quickly become a logistical — and regulatory — challenge.

FINRA’s Maintaining Qualifications Program (MQP) — which allows you to extend your latent period for your licensed to 5 years — was designed with exactly these scenarios in mind. But while it offers meaningful flexibility, it does not solve everything — particularly when state registrations come into play.

Here’s what you need to know.

What Is the MQP?

The Maintaining Qualifications Program (MQP) became effective on March 15, 2022, as part of FINRA’s broader overhaul of continuing education and licensing requirements. It allows individuals who leave a FINRA-registered firm to maintain their FINRA exam qualifications for up to 5 years by completing annual continuing education.

Previously, the rule was: if you were out of the industry for more than 2 years, your representative-level or state-level licenses expired (e.g., Series 7, Series 79, Series 24, Series 63). The SIE stayed valid for 4 years from the date you passed it.

The MQP creates an alternative path:

• You still have a 2-year window after leaving your firm

• But if you elect into the MQP during that time, you can extend your exam validity up to 5 years total

• This is contingent on completing annual CE requirements

• This does not apply to your SIE if you haven't passed any higher-level exams

For deal professionals who may step away between platforms, work on independent projects, or take time off between mandates, this can be a meaningful safety net.

Who Is Eligible for the MQP?

To be eligible for the Maintaining Qualifications Program (MQP) , you must:

• Have been registered with the same broker-dealer for at least one year, in the specific category or categories applicable to the licenses you wish to extend

• Elect into the MQP within two years of termination

• Not be subject to statutory disqualification

• Stay current with annual continuing education

Once enrolled, you can return to a FINRA firm within five years without retaking your FINRA representative-level qualification exams — assuming all requirements are met.

What Most Reps Don't Know: The MQP Doesn't Apply to the Series 63

The biggest issue we run into with reps who come to us wanting to get re-registered and who have been relying on the MQP during their time away from the industry, is that they don't know that the MQP does not apply to the Series 63 Uniform Securities Agent State Law Exam.

Unlike the Series 7, 82, 79, 24, and similar exams — the Series 63 is a North American Securities Administrators Association (NASAA) exam that is administered (not run) by FINRA. That means the states get the final say on its validity.

To address state exam expiration, NASAA introduced the Exam Validity Extension Program (EVEP), which is completely separate from the MQP. However, the big caveat here is that the EVEP is implemented on a state-by-state basis, states are not required to accept the EVEP, and many states have not opted into it.

Below, you can see which states have adopted the EVEP for AGs ("agents" of a broker-dealer such as investment bankers and private placement agents), as well as IARs ("investment advisor representatives").

You can always view the latest list of participating EVEP states on the NASAA website.

If a state does not participate in the EVEP:

• Your exam extension will not be recognized in that jurisdiction

• Your Series 63 (or equivalent) will still expire after 2 years

• You will be required to retake the exam to register in that state

This is true even if you are fully compliant with both the MQP and the EVEP.

Final Takeaways

The MQP reflects a more modern view of how careers in finance actually work — but from a compliance perspective, the system is still fragmented. Maintaining your ability to transact across jurisdictions is still complicated, since states all have their own stances on this.

For independent bankers and placement agents, the takeaway is simple: the MQP can preserve your federal licenses — but if you decide to leave the industry for more than 2 years, plan on retaking your Series 63 when you return — even if it's within 5 years. If you live and work and sell only in states on the EVEP list, you may be able to then rely on the EVEP extension. However, that is very rare in our industry and may limit your options mid-deal.

Here at Britehorn Securities, we always help you figure out how to stay on the right side of FINRA and state regulations. Contact us to learn more about working with us.