The Personal Finance Society has thrown its weight behind work-based assessments and has submitted a proposed model for alternative assessments to the FSA.
It supports work-based assessments provided they are robust, independent and have no short-cuts or exemptions.
The PFS submission says there would have to be an appropriate number of assessors who are appropriately qualified and independent and have the time to carry out the assessments. It proposes a mixed format assessment containing a technical knowledge assessment under exam conditions alongside an oral or work-based assessment.
It says: “The CII believes any transitional assessment developed as part of RDR should be a mixed-format assessment, containing some formal knowledge assessment in exam conditions in addition to any oral or work-based assessments. We are working to develop an alternative assessment model to take into account FSA and Ofqual view on the required standard of the process.”
The PFS says the technical content of the assessments and learning outcomes must match the exams on which they are based and be of the QCF level 4 standard of 37 credits, or 370 study hours.
The response says the CII has considerable experience and expertise in the construction and conducting of a range of assessment methods. It says purely oral versions of examinations, proposed by the FSA in its RDR CP, are less consistent than other forms of assessment due to the increased risk of subjectivity.
The response warns against qualification arbitrage as standards across different awarding bodies may not be the same.
The PFS believes the 2012 timetable is achievable but the FSA must maintain a regular check on the overall progress of advisers moving towards the new benchmark.
It adds there must be clarity on transition arrangements for trainee advisers as some firms have deferred or stopped their recruitment programmes until there is more certainty. It wants to know whether existing trainees will be permitted to continue advising under supervision until appropriately qualified.