Per a recent conversation with CDR, it was learned that the level process is not considered by CDR when making portfolio compliance decisions. Use the levels to guide yourself in your portfolio plan only. As long as your learning need is congruent with the ones you have on file with CDR, your portfolio should be valid regardless of the level set.
Questions may be directed to CDR at:
CDR
120 Riverside Plaza
Suite 2000
Chicago, IL 60606-6995
800-877-1600 ext:5500