FAIS - Fit & Proper: CPD component

As we near the first deadline of the 31st of May 2019 for the CPD requirement there is a busyness in the industry as many realise that the deadline is creeping closer.


As we near the first deadline of the 31st of May 2019 for the CPD requirement there is a busyness in the industry as many realise that the deadline is creeping closer.

The busyness ranges from those who are urgently seeking confirmation of the activities they have completed and taking stock of their CPD achievement to date, or those who are urgently looking for CPD approved activities to complete before the deadline date.

Many are seeking a central repository they can consult with to confirm their current standing.


So here are some top tips to assist you in the hustle of the busyness:

1.     Check to ensure that the content of what you are attending or completing is relevant to you.

2.     Confirm that the CPD provider / host will supply you with a confirmation record which also details which professional body has approved the activity and what CPD rating was


3.     Ensure you receive the confirmation of your attendance or completion of the CPD activity.

4.     Submit confirmation documents through your compliance process for recording.


So why the fuss?

The FSCA brought a few restrictions to the definition of CPD in their Board Notice 194 of 2017.  These restrictions include that for FSCA purpose CPD Activities must:

·      show completion;

·      be verifiable; and

·      cannot be product training or qualification study.


Show completion and be verifiable:

This requirement means that for attendance CPD providers/hosts must show that persons attending were there for the full duration of the session.  Therefor you are asked to sign in on arrival and also to sign out when you leave. If we cannot show both signatures, we cannot issue a certificate for that person.

For online activities, showing completion is a little easier as an online assessment on the content is easiest to show engagement with the content. Generally, the CPD pass mark is a minimum of 60% as required by Professional Bodies for CPD purposes.

As for Verifiable, the signed attendance register is helpful, but this is best done by providing a CPD certificate to each attendee or that can be downloaded from a CPD platform and records your attendance.

Recording process:

Originally in the Draft Board Notice, which was published for comment in 2016, the CPD definition included the requirement for Professional Bodies to track CPD activities.  However, this was removed from the definition, and the responsibility was shifted to the FSP to track CPD Activities for their own staff.

This is also an expansion of the FSP’s responsibility to plan CPD which is fit for purpose for their specific representatives and Key Individuals based on their development needs as indicated in Section 32 of the Board Notice.

Therefore, there is no central repository of CPD records, as all of our Professional Bodies are voluntary organisations and none are Statutory. This means that they may well only provide services to their members and may insist on payment for services for non-members.

It was also for this reason that the Professional Body requirement in this process was only to approve and rate CPD activities.


Restriction on Content – no Product Specific Training or Qualification Study:

This restriction is intended to simplify the distinction for CPD, as Product Training and Qualifications are part of the approval requirement either to initially be appointed as a Representative or to continue practicing as a Representative for additional products which are newly added to an Advisors portfolio.

Product training is specific to an individual product of a product supplier such as a UMA or Insurer, and is therefore unique to each persons’ authorisation for which products they may advise the public or clients on behalf of an Insurer or UMA.

However, any risk information that influences risks, market trends and legislative updates related to insured assets or insurance covers provided by insurance policies would be deemed asCPD content for the FSCA’s purposes.


Camargue CPD Summit 2019:

I will be presenting at the CPD Summit on the A-Z of CPD and happy to answer any other questions.

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