FINRA published an FAQ about the new Series 99 Operations Professional exam, covering some of the administrative details concerning its implementation.  FINRA explains that there will be no “grandfathering” based on prior operations experience to avoid the new Series 99 exam.  The only way out of the exam is to hold a valid license in another category (e.g. Series 6, 7, 24, etc.).  Firms must identify “Day-One Professionals” by submitting U4s between October 17 and December 16, 2011.  The exam window for Day-One Professionals will stay open until October 17, 2012, unless such person fails the exam.  Series 99s will be subject to Firm Element and Regulatory Element continuing education requirements.  The Series 99 has no prerequisites and does not serve as a prerequisite for any other exam. 

OUR TAKE: For those procrastinators out there, October 17 is only 10 days away.   If you haven’t begun the process of identifying who must take the Series 99, no time is like the present.