January 31, 2016
SELF-REGULATORY ORGANIZATIONS;NASDAQ OMX BX, INC.;NOTICE OF FILING AND IMMEDIATE EFFECTIVENESS OF PROPOSED RULE CHANGE TO AMEND SECTION (a)(6) OF RULE 1120 (CONTINUING EDUCATION REQUIREMENTS)
Being a citizen over the age of 60 years, I am for any procedures that will assist in making the "learning" atmosphere more comfortable and "interesting" to the learning participant. Being that this world is and has become a circle of technology, it is, of course, a wonderful idea to the upper staff to provide a web-based delivery of the Exchange's continuing education (CE) program, instead of using a test center.
The CE requirements would apply to all registered persons and would consist of periodic computer-based training on several important aspects of any organization. These aspects include, but are not limited to the following: regulatory, compliance, ethical, and supervisory subjects and sales practice standards (these are all mentioned in the proposal), which must be completed within prescribed time frames. Of course, every organization wants the best training for their employees, at the least expense.
I am assuming that this change is being proposed not only because of the technology aspect, but because of monetary reasons as well. It was stated in the proposal that there were problems with diminishing utility in the test center and in-firm delivery methods. And there is the expense of the traveling involved to and from the test center (more expense for the organization). It was stated in the proposal that it would be less expensive to utilize the web-based CE program than the test center program.
I understand the concern involving the monetary issue. I understand that organizations desire to use as less monetary means as possible, but continue to provide adequate training. I would like for you to take in consideration the fact that there are more "seniors" staying in the work field, for whatever reasons that are important to them and their livihood. With more "seniors" in the work force, there are problems (sometimes) with the understanding of all this technology. The younger generation has grown up with computers, tablets, facebook,twitter and other gadgets out in the world of technology. But, there are some, in the older generation, that have little or no knowledge of the technology. Without this knowledge, the workforce will probably lose some great senior participants. Even though it is a monetary gain to go to a web-based program for the CE program, please consider the senior workers. It may be more feasible for you to offer EITHER the test-center OR the web-base training for the employees. Allow them, the participants (the employees) to make the decision of what method that they would prefer. In allowing the employees to make a choice, you will have a better balanced and cooperative group of people. This would definitely be true, ESPECIALLY among the senior employees that have not grasped this technology world. Make it SIMPLE and you will have more happier and dependable employees.
I have no documents or statistics to provide to prove or disprove my opinion on this matter. I only have personal experience. I am attending both a web-based and in-class courses at my local college. The in-class course has the personal interaction with your professor that you may miss out on when involved in a web-based course.