Rheece's lapsed FINRA licenses — Series 7 and 63, CE missed December 2025 — 2026-09-09

Rheece's first direct ask of JT on the record. Two messages on 2026-09-09 at 12:51 PM ET, twenty minutes after the Compliance Department's 2026 IAR Continuing Education reminder went out; JT's holding reply came 2026-09-11.

Summary

• Rheece holds a Series 7 and a Series 63 obtained in spring 2024 at Wells Fargo. He left Wells Fargo in spring 2025 and was told the licenses stayed "good" for two years.
• His last role, compliance consulting with CCOs, did not need the licenses, and he missed the FINRA continuing-education window in December 2025.
• His question: "Is there any hope of maintaining my licenses? Or are they essentially defunct?"
• One minute later he added the framing himself: "TCM doesn't plan to hold the licenses so its okay if failing to do CE does make them defunct now." The Firm is an RIA, not a broker-dealer, so nobody at TCM can hold FINRA registrations; he appears to know this.
• JT replied two days later: "Let me look into this and I will circle back on it!" Rheece thanked him. No answer yet.
• This is a personal-registration question, not a firm compliance item. The IAR CE reminder that went out the same morning covers NASAA IAR CE (12 credits by 2026-12-31), which is a different regime from the FINRA CE he missed.

Decisions

• Nothing decided. Rheece has already accepted that the licenses may be gone.

They asked me for

• Rheece Hilliard: whether his Series 7 and 63 can still be kept after missing the December 2025 FINRA CE deadline, or whether they are defunct.

I asked them for

• Nothing raised.

Concerns and frustrations raised

• Rheece Hilliard: mild — he flags the lapse himself as unfortunate and pre-empts the answer. No frustration with the Firm.

What they are focused on

• Rheece Hilliard: understanding where his personal registrations stand now that he is at an RIA.

Doable / not doable / needs a decision

• Answering the question → doable from public FINRA rules (the two-year window after leaving a member firm; the Maintaining Qualifications Program and its CE deadline); the answer is factual and does not need a firm decision.
• Restoring the licenses through TCM → not doable; TCM is not a FINRA member and cannot sponsor or hold them.

Action items

Mine

• Look up the FINRA rule on the two-year post-termination window and the MQP CE deadline as applied to a December 2025 miss, and give Rheece a straight answer — target 2026-09-15 — (Notion: not pushed)

Theirs

• Nothing pending on Rheece.

Suggestions for me

• Answer in two or three sentences. He has already told you the outcome he expects; what he needs is confirmation and, if there is any reinstatement path (for example FINRA's MQP if he enrolled before the deadline), the specific date that governs it.
• Separate the two CE regimes explicitly in the reply so he does not conflate his FINRA lapse with the IAR CE reminder that went out the same morning.

Notable quotes

"Is there any hope of maintaining my licenses? Or are they essentially defunct?" — Rheece Hilliard

"TCM doesn't plan to hold the licenses so its okay if failing to do CE does make them defunct now." — Rheece Hilliard