A look at the common areas for error when it comes to advisers maintaining competence
Time and again, we encounter the same issues when reviewing a firm’s training and competence scheme. If you are subject to continuing professional development recording requirements, you may find the following tips useful.
Obtain and record regularly
We often see CPD recorded annually, just prior to the renewal of a Statement of Professional Standing. If CPD is not recorded in a timely manner, it can be difficult to remember what you did and why.
Setting yourself targets to complete CPD on a regular basis will help you achieve your annual requirements.
Record statements promptly
Reflective statements are often poorly completed and usually rushed, due to being carried out at the last minute. Sometimes it is because the individual does not realise what they need to record.
One accredited body has stated the following to clarify what needs to be done: “A reflective statement is a statement of the outcomes achieved. It should answer questions such as whether the activity met your learning needs and how it has benefited you professionally, and include how you felt about the activity, and the effectiveness of the learning and learning method.”
There is no prescribed length to a reflective statement, but it should reflect the length of the activity.
For example, one lasting a day should therefore be more detailed than one taking 30 minutes.
We often come across examples where a third party (such as an administrator or assistant) has completed CPD on behalf of the adviser. The third party can record the activity, content and time spent, but don’t ask them to complete your reflective statement without any input from you.
They won’t be able to. Reflective statements should always be unique to the person who is undertaking the activity.
If you can’t record your CPD straight after the activity took place, make a note of it so you can refer to it at a later date and retain evidence.
An accredited body can ask that you enhance your records, so do all you can to get it right first time.
Make it relevant
Many business owners advise and are also their firm’s money laundering reporting officer (CF11) and compliance oversight (CF10).
In these cases, we often see CPD recorded in relation to their advisory role, but not in respect of their other ones. We see similar occurrences when advisers provide advice in several specialist areas, such as pension transfers, long-term care and equity release. Review what you have recorded to ensure it reflects all of your roles.
The supervisor’s role
Supervisors should review their staff records thoroughly, looking beyond the number of hours recorded and instead considering their relevance (referring back to a development plan).
Dependent on the frequency of one-to-one meetings, supervisors may need to review the records more often. Having access to records 24/7 will help.
CPD and the IDD
If you are involved in the distribution of insurance products, you must complete a minimum of 15 hours of CPD in relation to your activities in this area.
These 15 hours do not come in addition to the standard requirement of 35 hours (of which 21 must be structured) that apply to most IFAs. Neither is there a requirement for these 15 hours to be structured.
This year, we’ve received lots of requests for protection-related CPD. This is an activity many people are involved in and will support meeting your Insurance Distribution Directive CPD requirements.
But don’t forget there are many other insurance-based products where relevant CPD will also count towards your minimum 15-hours IDD requirement.
If you also advise on retail investments, there’s likely to be some overlap, as some of the 15 hours required may relate to retail investment products, where you already have a requirement to complete 35 hours of CPD.
That said, you must additionally establish that the learning you have undertaken is appropriate, based on the products you recommend to others and/or the products your clients hold.
While your learning does not need to be product-based, you must apply it to an insurance-based product and it has to be relevant. This should then be documented in your reflective statement.
Ian Grundy is head of business risk at Threesixty