Continuing education (CE) may not be the most exciting part of the job, but for regulators, it’s non-negotiable—and they're cracking down hard on violations. This week, Finra sanctioned a registered representative for outsourcing his CE requirements, marking another disciplinary action in a growing list of similar enforcement cases.
According to Finra, Frances Smith—formerly with Commonwealth Financial Network—falsely attested in February 2023 that he completed the CE coursework necessary to renew his New York insurance license. In reality, regulators say another individual completed the training on his behalf.
To settle the matter, Smith accepted a one-month suspension from the industry and a $5,000 fine, without admitting or denying the allegations. His legal counsel, Anthony Paduano of Paduano & Weintraub, did not respond to inquiries. Commonwealth Financial Network also declined to comment.
This case reflects Finra’s intensified scrutiny around CE compliance. Regulators are sending a clear message: misrepresenting CE participation is a serious breach, and enforcement will be swift. Over the past year, Finra has fined and suspended dozens of advisors for similar conduct related to insurance CE requirements in New York. Those who cooperated with investigations typically received penalties in line with Smith’s. Those who didn’t were expelled from the industry altogether.
Smith has held an active insurance license in New York since 1992. Like many states, New York mandates license renewal every two years, generally including a 15-hour CE component. Finra alleges Smith went a step further—having someone else complete 18 hours of CE training for him, violating Finra Rule 2010, which requires members to uphold high standards of commercial honor and just and equitable principles of trade.
The takeaway for advisors is straightforward: CE compliance is not just a box to check. Whether it’s fulfilling insurance licensing obligations or meeting firm-specific education mandates, regulators expect full transparency and personal accountability. Cutting corners—even on what may seem like administrative tasks—can jeopardize a license, a career, and a firm’s reputation.
