FINRA testing in the time of COVID-19

When covid-19 took hold in the United States, large parts of the economy were closed to stem the spread of the virus.  The administration of FINRA licensing exams has not been immune to the shut down. This crisis has caused unique problems and challenges for regulators, broker-dealers and test-takers alike. As the Prometric test centers closed, test-takers who were preparing for their financial services exams were left in a lurch. Many individuals who had been preparing for months and who had invested hundreds of hours to ensure success, had their examinations canceled or were shut out completely. Broker-dealers during this time have not fared any better. From a regulatory standpoint,  broker-dealers have not been able to meet the licensing requirements for agents and principals. As a result, many firms have incurred substantial costs and delays as they try to meet their staffing and organizational goals. As the industry grappled with the uncertainty relating to the duration of the closures,  FINRA began searching for a potential solution. FINRA has taken extraordinary and somewhat shocking steps to keep the licensing process moving forward. In response to the covid-19 pandemic, FINRA has worked closely with Prometric to develop a system which would allow test takers to sit for their FINRA licensing examinations remotely. Initially FINRA will offer the SIE, Series 6, 7, 65 and 66 examinations online. Remote testing for these examinations was scheduled to begin May 11th with test dates beginning May 24th. However, FINRA stated that more time was needed to validate the system. FINRA finallly launched online testing in July, students who would like to take their examinations in this format may take their exam from a personal or work computer provided that there is a video camera attached allowing Prometric to monitor the testing session.

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For years industry participants and test-takers have been clamoring for the opportunity to take the examinations online and for years it had been out of the question. The proprietary and confidential nature of the examinations are absolutely essential to ensure their validity.  Perhaps prior to now, the technology had not been available to ensure the safety of the examination or to properly monitor test-takers from a distance. FINRA clearly believes that it has developed the systems required to administer examinations remotely. As it is currently outlined, Prometric staff members will be monitoring test-takers through the video cameras to ensure candidates are not using reference material and to ensure their identity. Further, FINRA has indicated that Prometrics will be monitoring the session using ”other methods”.  We can only speculate as to what these other methods may be. However, this would seem to indicate that there will be technology embedded either in the examination itself or placed on the test-takers computer to further ensure the validity of the testing process. If successful, FINRA plans to further rollout remote testing to other examinations including principal exams such as the series 24 and 26.

While FINRA writes  the exam questions for most of the tests it administers, the North American Securities Administrators  Association writes the questions for the  series 63, 65 and 66 and the National Futures Association is responsible for writing the content for the series 3, 30, 31, 32 and 34 examinations. FINRA administers these exams on behalf of NASAA and the NFA.   FINRA has clearly obtained the consent of NASAA  to allow for the administration of the series 63, 65 and 66 exams remotely.  The successful implementation of the remote testing would lead one to believe that the NFA examinations cannot be far behind. The administration of financial industry examinations remotely is a huge step forward. Perhaps it took the extreme Impact of covid-19 to demonstrate the importance of this advancement. Like any other advancements, the administration of examinations remotely is fraught with potential issues.  Many test-takers in the past have tried to cheat on their FINRA exams by taking notes in the test center or by leaving notes in the bathroom to review on a break. Other more nefarious individuals have gone as far as to hire imposters to take their examinations for them. These are just two examples of how people have tried to avoid putting in the hard work required to pass these tests. In order to ensure individuals are who they claimed to be, FINRA began requiring test-takers to be fingerprinted at the test centers.  Many broker-dealers and test prep providers have sent individuals to take the examinations simply to obtain the questions on the exam. Once the questions were memorized, the broker-dealers and test prep providers would use this information to help others prepare for the exams. This  practice is a significant violation of Industry regulations and it compromises the validity of the test and the integrity of the industry as a whole. Many test prep providers have faced substantial fines and legal action from FINRA for just this practice. Many individuals have found themselves banned from the industry for cheating on these exams. FINRA must be extremely diligent in the administration of online examinations. Test-takers should think twice before trying to outsmart the regulators as the consequences will be extreme. 

As the covid-19 pandemic has decreased, Prometric has begun to open up testing centers across the country. Prometric is open for essential examinations only. Financial services exams have been deemed to be essential and test-takers therefore may schedule examinations at local testing centers, if available. Prometric has developed significant guidelines to ensure the safety of all test-takers. Social distancing will be observed by only allowing a small number of test-takers in the facility at any one time. So, in this stage of the crisis we have a blended test-taking solution. Online testing through FINRA’s new remote testing facility and traditional testing in a Prometric Center. We are cautiously optimistic about the use of FINRA’s online testing center. However, if problems arise and the crisis passes, we could imagine FINRA reverting back to administering the exams only through approved test centers.  

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