“New year, new you” is the marketing cliché that is trotted out at this time of year but even if you are not planning on a programme of self-improvement which involves a Tai Chi course or introduction to Moroccan cuisine there is still planning to be done for advisers.
The 35 hour CPD requirement introduced by the RDR does allow advisers to undertake a mix of structured or unstructured learning but many advisers say the easiest way to achieve this target is to plan their CPF programme in advance.
The 35 hour requirement is equal to a full working week for someone working seven hours a day and although many advisers work considerably longer hours, this is a huge amount of time to fit into a crowded work schedule.
Unstructured CPD can cover reading or learning determined by an individual adviser, while the FCA defines structured CPD as “participating in seminars (web based or in person); lectures; conferences; workshops; courses; and completing appropriate e-learning”.
To qualify for their annual statement of professional standing, an adviser needs to complete at least 21 hours of structured learning. In December, several professional bodies reported some advisers were having problems meeting their CPD requirement in time.
Chartered Insurance Institute director of financial services and insurance markets Steve Jenkins said: “In some cases advisers are struggling to record their CPD correctly and demonstrate that the activities are a solution to a specific, identified need.”
The Institute of Financial Planning said some advisers were reporting CPD activity that was not relevant or were failing to adequately record or demonstrate CPD had taken place.
Structured CPD is available in a number of different formats and from many sources. These include seminars and workshops, online tools such as webinars, videos and questionnaires which record your learning progress.
CPD is offered by product providers, industry bodies, such as the CII, IFP or Institute of Financial Services, networks and support service providers and even from Money Marketing’s own CPD Centre.
But this wide variety of subjects and learning methods can lead to a confused and haphazard approach to meeting the annual CPD requirement if it is not planned carefully.
IFP director of professional standards Sam Rees-Adams says there are many lessons to be learnt from the first year of the new CPD requirements. For advisers this is often adequately recording their programme of CPD activity, while providers of the crucial statement of professional standings often find the main problem is dealing with the way CPD records are submitted.
Rees-Adams says: “We may not quite have received a shoe box full of paper, but some responses haven’t been far off. In the vast majority of cases, the issue hasn’t been a lack of CPD (which is pleasing in itself) but rather a lack of documentation.”
To avoid any of these problems occurring again this year, the main piece of advice is plan your CPD programme in advance.
Rees-Adams says: “What we have noticed above all, is that the most effective CPD comes as the result of planning. The best advice I can give you for CPD in 2014 is to start with your plan. Know what you want to achieve, choose activities that will get you there, reflect on what you’ve learned and keep records as you go along.”
New inducement rules should not impact on CPD
Last week, the FCA unveiled its final guidance on adviser inducements, which will ban providers paying for “extravagant” hospitality, support service payments and exclusive distribution arrangements.
The FCA says it has found evidence of provider payments undermining the spirit of the RDR and has given just three months for such practices to cease.
Support services arrangements can include the provision of training for advisers but lawyers say the new rules should not affect providers ability to provide such training.
Pinsent Masons partner Bruno Geiringer says: “The new guidance supports the RDR objectives to reduce provider bias and applies to all providers, and not just life insurers, of retail investment products and advisory firms.”
However, the FCA’s guidance states that as long as providers are not providing training or training materials on an exclusive basis and that the costs are not disproportionate, training from product providers will fall outside the new rules.
The FCA’s new guidance states: “A provider giving an advisory firm training on the features and benefits of its products or services, or subject areas relating to the adviser’s continuing professional development, is unlikely to impair its compliance with the client’s best interests rule if the training is made reasonably available to all advisory firms that could recommend the provider’s products or services on an equal basis.”