Employee Compliance Certification Tracking Checklist Template

What the Certification Tracking Checklist Covers

1. 1
   Phase 1

   Phase 1: Refresh the Certification Register

   4 tasks

   Assigned to a compliance analyst. The register is only as good as the HR feed behind it.

   • Open the cycle record and set the cut-off date — carry forward open items and mark whether this is the annual attestation cycle
   • Reconcile joiners, leavers and role changes from HR against the register — every change since the last cut-off is reflected
   • Map each role to its requirements — registrations, licences, certification functions, CE and attestations
   • Confirm no new joiner started a regulated activity before qualifying — registration approved, certificate issued, or qualification held or supervised
2. 2
   Phase 2

   Phase 2: Check Expiries, CE and Registrations

   6 tasks

   • Run the expiry report for the next 90 days — licences, certificates, SPS and state registrations, each with an owner
   • Check FINRA Regulatory Element status for every registered person — due by 31 December; anyone not started by the fourth quarter is chased
   • Check IAR, insurance and other state CE progress against each renewal date — record which state rule each person follows
   • Check SPS renewals and CPD logs for UK retail investment advisers — at least 35 hours in each 12 months, 21 of them structured
   • Confirm Form U4 amendments and FCA Directory updates were filed on time — U4 within 30 days (10 for a statutory disqualification); Directory within 7 business days
   • Confirm whether any UK certificates fall due in the next 60 days — a Yes adds the fit and proper certification phase to this run
3. 3
   Phase 3

   Phase 3: Chase and Collect Evidence

   5 tasks

   • Send reminders to each person with an outstanding item — copy the line manager and state the deadline
   • Collect quarterly transaction reports from access persons after each quarter end — due within 30 days of the quarter end under SEC Rule 204A-1
   • Attach completion evidence to the register — CE records, licence renewals, SPS copies and U4 or Directory confirmations
   • Record agreed exceptions — leave, exam booked or role change pending, each with an end date
   • Record whether any certification was lapsed or overdue at the cut-off — a Yes adds the escalation phase
4. 4
   Phase 4 — If Lapses Found

   Phase 4: Escalate Lapses and Restrict Activity

   5 tasks

   Shown only when a lapse or overdue item was recorded at the cut-off.

   • Restrict each affected person from the activity the certification covers — CE inactive FINRA registrants must stop all registered activity
   • Notify the supervisor, line manager and HR in writing — record who was told and when
   • Assess whether a regulatory filing or notification is needed — Form U4 or U5 amendment, FCA Directory update or a conduct breach report
   • Agree a remediation date and restore activity only on evidence — the completion record is attached before the restriction is lifted
   • Record the root cause — missed reminder, register gap or unmapped joiner, and fix the process
5. 5
   Phase 5 — Annual Only

   Phase 5: Annual Attestations

   6 tasks

   Shown only when the cycle is marked as the annual attestation cycle in Phase 1.

   • Collect code of ethics acknowledgements and annual holdings reports — supervised persons acknowledge the code; access persons report holdings annually
   • Collect outside business activity and private securities transaction declarations — compare them with notices received during the year
   • Collect conflicts of interest and personal account dealing declarations — gifts, directorships and personal trading
   • Collect policy acknowledgements — handbook, AML, information security and any policy changed this year
   • Hold the annual compliance meeting and record attendance — required at least annually by FINRA Rule 3110(a)(7)
   • Complete the FINRA Firm Element needs analysis and written training plan — FINRA Rule 1240(b) requires both at least annually
6. 6
   Phase 6 — UK Certification

   Phase 6: UK Fit and Proper Certification

   5 tasks

   Shown only when UK certificates fall due. The approval is assigned to the named SMF or HR lead chosen in Phase 1.

   • List the certification staff whose certificates expire in the next 60 days — plus anyone whose role has changed
   • Gather fit and proper evidence against the FIT criteria — honesty, integrity and reputation; competence and capability; financial soundness
   • Check conduct records, training and qualifications for each person — conduct breaches, discipline, Conduct Rules training and TC competence
   • Approve or refuse each certificate — the approver records the decision; certificates name the function and the dates of validity
   • Issue certificates and update the FCA Directory — within 7 business days of any change to a directory person
7. 7
   Phase 7

   Phase 7: Report and Sign-Off

   4 tasks

   Assigned to the compliance officer by name. The analyst who ran the cycle cannot sign it off.

   • Compile the cycle summary — current, expiring, lapsed and restricted counts and open exceptions
   • Report to the compliance committee — lapses, restrictions and repeat late completers, with owners
   • Compliance officer review and sign-off — record Approved or Returned, with any conditions
   • Confirm every open item has an owner and a due date, then close the run — open items carry into the next cycle