You took a better post with a different company in Brownsville, your renewal is coming up, and you ask HR for a copy of your continuing education record. They do not have one: you did that training when you worked somewhere else. So where does that leave you?

Whose Records Are These, Anyway?
Three parties hold a piece of this, and the split explains why officers who change employers so often find a gap. Under §35.161(a) your employer maintains proof of completion in your personnel file, but that is the employer you were with when you completed the training. Under §35.162(b)(3) the school issues a certificate of attendance and retains its records for two years. And under §35.161(m) you keep your certificates of completion for two years and furnish copies to the department on request.
That third obligation is the one that travels with you. The license is yours, the renewal is yours to file. §35.161(a) also requires you to indicate completion on the renewal application, and a new employer’s empty file does not relieve you of it. Our certificate for this course is the one referred to as PSP 31; keep your copy somewhere that is not a former employer’s filing cabinet.
What Exactly Do the Six Hours Have to Be?
- Six hours of continuing education, per §35.161(g), for commissioned security officers and personal protection officers.
- Earned by completing the renewal portions of the Level III or IV training course, as applicable.
- Taught by department-approved training schools and instructors: the same subsection says so.
- Completed within the two-year period preceding your license’s current expiration date, which is the validity test §35.161(n) applies.
- Plus, for a commissioned security officer, a firearms proficiency certificate submitted with the renewal application.
And the ordering matters: §35.161(a) bars submitting the renewal application until the minimum hours have been earned. You can verify all of it in 37 TAC Chapter 35.
Can My New Company Just Train Me In-House?
Not for this. §35.162(d) states that the in-house continuing education exemption for companies with ten or more licensed employees does not apply to commissioned security officers or personal protection officers, and §35.162(f) adds that credits earned through outside entities may not be used for them either. Whichever company you work for, and however good its internal program is, your six hours come from an approved school.
Am I Even the Kind of Officer This Applies To?
If you are unarmed on a Level 2 non-commissioned license, no. §35.161(b) exempts noncommissioned security officers from continuing education entirely. If you are armed, yes, and it is worth being precise about which credential you hold. Level 3 is the commissioned security officer. Level 4 is the personal protection officer, a distinct license for close protection work rather than a step up from Level 3. Both renew through the renewal portion of their own course, which is why one class serves two audiences.
Why Officers Move Around So Much Down Here
Brownsville sits at the end of a coastal corridor where port and marine terminal operations, manufacturing and assembly plants, warehouse and cross-dock facilities, hospitals and a busy retail trade all hire armed coverage, frequently through contract firms rather than directly. Contracts change hands, and an officer can keep the same post and the same gate while the name on the paycheck changes twice in three years. Sitting at the far southern tip of the state also means the nearest classroom training is rarely a short drive.
Both of those are arguments for taking the classroom portion 100% online, which is how we deliver it. What the online enrollment covers is the online training only: the in-person firearms qualification is not included and is arranged separately once you have finished. If you are weighing which class you actually need, our FAQ page is the fastest way to sort it out.
What If the Gap Was Years, Not Months?
§35.141(d) requires an inactive or expired licensee who has not been employed in the industry for three years or more to submit current training certificates to the department, which frequently means the full Level 3 commissioned security officer course rather than renewal training. Military service members have more latitude than most: §35.182 grants two additional years to complete a continuing education or other renewal-related requirement, and §35.181 waives late-renewal penalty fees for them. For anything about the license itself, the Texas DPS Private Security Bureau is the authority.

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