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Fay Goddard: Three steps to filling the gap

Three steps to filling the gap

To read or not to read – that is the question many advisers are asking in relation to qualification gap-fill. For those not yet facing this part of the RDR challenge, gap-fill means bridging any gaps in learning outcomes that have not been covered through examination. With thousands of advisers already holding a level four (or above) qualification, undertaking structured CPD to plug their personal gaps is top priority.

We know this by the numbers attending PFS gap-fill sessions that we are running around the country, where the majority of regional gap-fill events have reached maximum capacity.

However, following publication of the FSA’s policy statement PS11/01, there is one aspect that is causing some consternation and debate.

To quote the FSA: “Gap-fill should be structured, rather than unstructured, CPD. However, if structured CPD is not available to fill the gap identified, then an adviser may complete the gap by reading suitable material. We expect that such cases would be for a minority of gaps, if any.”

Before jumping to the conclusion that this message means that “reading” is automatically unstructured, we need to be clear about the difference between structured and unstructured CPD. The Chartered Institute of Personnel & Development has broadly defined structured CPD as following a three-step process:

Training needs analysis: identifying gaps in competence, knowledge, etc, giving rise to desirable future learning outcomes

Learning interventions: activities, regardless of type or medium, undertaken to address the required learning outcomes specifically

Review: establishing that the intervention did its job, and confirming that the learning outcome has been achieved

Point two is particularly important as, in our view, provided the three steps are followed, reading learning material that has been created to meet a clearly defined learning outcome can meet the structured CPD definition. An individual would need to complete the third step by considering carefully whether they have fully understood the material and verifying that the activity has met the learning outcome.

This is a very different proposition to reading topical articles or even technical material that may be very useful, but not designed to meet specific learning needs. So there are two types of reading.

It is on the former basis that the CII has built its gap-fill tool, so we are confident that provided advisers undertake the second and third steps diligently they will have met the requirement. It is also worth noting the ultimate decision regarding verification of whether an adviser has fulfilled the requirement will be down to the FSA accredited body that an adviser selects to provide their statement of professional standing. The CII, along with other bodies, has applied for accredited body status but the FSA will not be publishing the list of successful applicants until later this year.

Meanwhile, my advice to all of you with gap-fill obligations is to take advantage of all the support available that is designed to meet clearly specified gaps, whether it is attending events, accessing on-line training or correctly utilising specified learning material.

Fay Goddard is chief executive of the Personal Finance Society


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There are 8 comments at the moment, we would love to hear your opinion too.

  1. Over 6000 hours of CPD over 22 years in the Industry, plus the experience of advising loyal clients without a complaint over those years, plus being a chartered engineer with 22 years of senior management experience with International Companies and being a member if the Institute of management. All this at the age of 72 amounts to ZERO. I’m only a certified level 3 adviser (with mortgage plus qualifications) AND AM NOT EVEN ALLOWED TO ADVISE AN 18 YEAR OLD ON SETTING UP AN ISA, PENSION OR SAVING SPLAN. WHAT A JOKE THIS INDUSTRY HAS BECOME!!!!

  2. Brian Aspinwall 5th April 2011 at 12:41 pm

    We all feel for John, we now live in a tick box world and they like nothing more than to add new boxes. It is about time that we define once and for all what qualifications are required to give advice. Some consideration should be given to experience at the time we convert to this qualification. As for GAPs how can you not have them as UK Gov loves to change the law almost everday day. What is needed is an annual update learning program.

  3. Incompetent Regulators Awards Team 5th April 2011 at 1:00 pm

    The world of financial services in the UK has gone from good prducts and good production with consumer and adviser incentives. This all worked.

    Now. Beaurocratic bullsh*t non jobs getting in the way of real work and production. All from regulations and concurred with the likes of Fay Goddard who also has a non job.

  4. I feel Fay Goddard has misrepresented the IFA corner in pursuit of CII/PFS aggrandisement in the eyes of the regulator, so much so that in my opinion every self respecting IFA should turn their back on her, her views and the PFS which has lost direction. Just read this article! These people make a profession out of the bastardisation of common sense. They are to financial services what the public sector is to private enterprise.

  5. Fay Goddard is High Priestess 5th April 2011 at 3:32 pm

    In the beginning we had the LIA who were motivational and inspirational taking many ideas from the MDRT.

    Then we had SOFA, egg heads that charges fees without linking to results and whose only future lay in passing exams. The sort of guys and gals we called rate book refuges, they never sold but had all the answers.

    SOFA took over LIA and the PFS was born. So uninspiring was this group that their future rested with the regulators. The PFS hope was that compulsory membership would secure their future so they worshiped at the altar of the FSA and Fay Goddard is their High Priestess

  6. First we have Aifa apologising for messing up on the qualifications front. Now we have PFS hurriedly making excuses for this colossal dog’s dinner called ‘gap fill’.

    What’s worse is that they see fit to patronise us with a “Janet and John” style reading lesson.

    Useless. Totally useless. Surprised there hasn’t been a stronger reaction to this article.

  7. Try teaching Grandma to suck eggs Ms Goddard.

    No advisor worth his/her salt will attempt to advise on something they know little about. We call on our professional colleagues to do it.

    Gap fill is getting to the stage where a brain surgeon will have to gap fill on toe surgery, even though he/she will never come close to doing it.

    And my 35 years qualified Chartered Accountant will have to re-take his exams because the syllabus has changed.

    This is past a joke!

  8. Fay so far you have 5 comments on this post. They are a reflection of what some would see as your (mis)representation of the financial services sector in your role at PFS. It is interesting that the Egyptian Revolution is seen to be a revolution of the people facilitated by the internet. IFA’s have taken a similar stance – they have bypassed you, the PFS and AIFA and gone direct to their MP’s. In so doing they have shown you and your views to be vacuous and without purpose. IFAs have represented themselves and have accomplished far more that you, the PFS and AIFA put together. Perhaps many will start to wonder why they are paying you to articulate such views when these are not reflected by the grass roots.

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