In the previous two articles we discussed the reasons for the introduction of CPD, and the obligations on CPD training service providers. Today we look at what could be expected from FSPs.
The specific conditions that apply to individuals (sole proprietors, key individuals and/or representatives) are:
(1) Individuals who participate in a CPD programme offered through a recognised CPD provider will be required to confirm, in the form and manner prescribed by the Registrar:
(a) their membership of the CPD provider;
(b) that they will adhere to the CPD programme offered through the CPD provider; and
(c) that they meet the CPD requirements of the CPD provider.
(2) An FSP (who is a sole proprietor), key individual and representative is required to:
(a) complete the requirements regarding CPD as specified in Part VII of the Determination of Fit and Proper Requirements for Financial Services Providers, 2008; and
(b) record individual achievements regarding CPD with the Registrar, using the mechanisms provided by the Registrar for reporting purposes.
(3) Individuals may apply for the recognition of an activity that meets the requirements for recognition as a CPD activity.
(a) The application for such approval must be submitted in the form and manner as prescribed by the Registrar.
(b) The Registrar will publish the approval of the activity for CPD purposes.
(c) Upon approval of the activity, individuals can upload their individual proof of attendance or participation in the form and manner prescribed by the Registrar.
(4) Individuals are required to:
(a) Confirm to the FSP that they have complied with the CPD requirements by way of self-certification annually.
(b) Retain verifiable proof of the CPD programmes and activities they participated in for a period of five (5) years after completion.
(c) Provide copies of documentary proof of attendance/ completion of CPD programmes and/or activities to the financial services provider on a quarterly basis.
(d) Record CPD activities in the form and manner prescribed by the Registrar, and must provide—
(i) title and date of activity/programme;
(ii) institution providing the CPD activities; and
(iii) number of learning hours.
(e) Where an individual is completing a CPD programme offered by a CPD provider, the individual is required to:
(i) check and confirm with the Registrar that the CPD provider has recorded the attendance and completion of the CPD programme on behalf of the individual; and
(ii) Where the CPD provider did not record the attendance and/or completion of the CPD programme the individual is required to update his/her own records within 4 months after year-end, for the previous year’s records.
The checks and balances built into the proposed system will hopefully prevent FSPs from being unfairly penalised for failure by CPD providers to record their progress.
We foresee that checking your status at the FSB will be similar to the way in which one can currently verify the status of an FSP on the Regulator’s website. If it is not recorded, you can take it up with the training service supplier. Those suppliers who do not play ball will be removed from the list of approved suppliers, which can be a costly exercise for them.
Is this another step towards shifting the focus away from the smaller players to the providers who can make a meaningful difference? We believe this to be the case, as will the introduction of Treat the Customer Fairly.
