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The Retail Distribution Review 2012. cisi.org. RDR Agenda . Statements of Professional Standing (SPS) – Policy and Application Process CPD Audit & the RDR. Implementing the RDR . In October 2011, the CISI became an Accredited Body (there are now eight in total)
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The Retail Distribution Review 2012 cisi.org
RDR Agenda • Statements of Professional Standing (SPS) – Policy and Application Process • CPD Audit & the RDR
Implementing the RDR • In October 2011, the CISI became an Accredited Body (there are now eight in total) • The SPS deadline is 31 December 2012 • Accredited Bodies are the only organisations that can issue SPSs • Accredited Bodies have a delegated role to ensure validation of professionalism requirements • Each adviser is personally responsible for applying for an SPS
CISI SPS Policy • Formed around FSA PS11/1 and handbook • FSA CPD rule commences 31 December 2012 for existing advisers • Newly qualified advisers • Difference between Basic and Full SPS • Prior to 31 December 2012, either CISI CPD scheme or RDR CPD acceptable
SPS Application Process • All SPS requirements must be met: • RDR compliant qualifications • Any appropriate gap-fill • Confirmation of adherence to APER • Confirmation of compliance with CISI Code of Conduct • 35 hours CPD recommended but not compulsory for applications prior to 31 December 2012 • Apply using the application form at www.cisi.org/rdr • Online form available in June 2012
SPS Application Fees PCIAM
Advisers need to complete their personal details in this section Advisers need to confirm their RDR specialist area here Advisers need to confirm their Individual FSA number here Advisers need to confirm their firm name here Advisers can obtain their Individual FSA number from the FSA website - http://www.fsa.gov.uk/register/indivSearchForm.do Advisers need to confirm their SPS date here
SPS Policy & CPD Audit • Full SPS application must be within 3 months of CPD year ending to ensure currency of CPD • May necessitate moving of CPD year (see website for guidance) • CPD audit may take place retrospectively after SPS issued – SPS will not be held up by audit process
SPS and the Firms • The CISI encourages firms to verify SPS applications due to the benefits this brings: • Ensures the form has been correctly completed, to avoid any delays with issuing an SPS • Be able to track when applications are being made and SPSs issued • Confirms the CPD being recorded is relevant to the adviser’s role • 45% of applications so far checked have required re-work or contact with applicant to confirm details
SPS – Application Problems Gap-fill not completed fully or at all 3,664 Application made outside of CPD 3 month window MCSI Some criteria not confirmed 7,480 Verifiers not confirming all fields Declaration not confirmed Firm FSA number entered by mistake (individual FSA number should be used, eg, ABC12345) Affiliates 847 Affiliates 829 Information not correlating between application form/CISI system/FSA register
SPS Application Timelines Need applications to be sent to us by 31 October 2012 to guarantee receipt by 31 December 2012 Applies to all advisers assessed as competent as at 30 June 2009 Firms have been given by the regulator a further 60 days after 31 December to receive the SPSs The CISI recommends that firms and advisers treat this 60-day window as a ‘safety net’ and is only used where absolutely necessary If using this ‘safety net’ an application needs to be made by 31 December 2012
Qualifications and Gap-fill • Gap-fill is used to ‘top-up’ legacy or appropriate qualifications that existed prior to RDR and is a ‘once only’ activity • Gap-fill can be undertaken at anytime, not just after the exams • FSA provided templates, CISI has pre-filled these, only for CISI and LSE qualifications on the website • Gap-fill templates are alreadyintegrated into the CISI CPD scheme and available online • Gap-fill is for qualifications, but crosses over with CPD and counts towards 35 hours CPD for existing advisers • CISI will recognise gap-fill from other Accredited Bodies
Examples John James Smith
Continuing Professional Development & SPS All CPD: • Minimum 35 hours, including part-timers • Minimum 21 structured hours • Must be in minimum 30 minute ‘bites’to be structured • Must be relevant to role • CISI CPD log fully RDR compliant • Must maintain knowledge by reference to current qualification standards and authorised activity • Have written learning objectives and documented outcomes • Needs to be logged on CISI log (or a CISI approved CPD scheme)
Alignment of the RDR & CISI Scheme See page 42 of RDR booklet
Case Study John James Smith 20% of members audited 5 weeks to compile evidence 825 members selected for audit in last 12 months; set to increase
Personal Conduct & Ethics In applying for the SPS, applicants must ensure that they comply with a “recognised Code of Conduct”. The CISI’s Code (shown on the right) is such a code and is also known as the Lord George Principles The CISI Code of Conduct is shared with the Worshipful Company of International Bankers and was revised in 2011. It will appear on the reverse of every Statement of Professional Standing issued by the CISI
The CISI’s Disciplinary Framework Summary See page 38 of RDR booklet
The CISI’s Disciplinary Process - Sanctions The CISI’s Disciplinary Process - Sanctions • Five CISI members have been formally disciplined to date • Sanctions available to the Disciplinary Committee are: • Reprimand • Severe reprimand • Fine • Suspension for a set period • Permanent expulsion • Additionally, Chartered status may be suspended for persistent non compliance with CPD requirements (RDR sanctions may also apply, e.g. withdrawal of SPS)
Waivers Are there any waivers? Very rarely! Any waivers for an SPS must be applied through the regulator directly, and not the CISI. The CISI understands that waivers are only granted in wholly exceptional circumstances; not because individuals have run out of time The CPD requirement of the SPS can be waived by the CISI only when an adviser is absent for statutory reasons (e.g. illness, maternity leave) for a substantial period of time. A basic SPS would be issued rather than a full SPS, as the CPD requirement will not have been met
What is an SPS? The certificate contains the individual adviser’s FSA Reference Number The certificate highlights the fact that the individual adviser has fully met the RDR qualifications requirements and holds at least a Level 4 RDR-relevant qualification The certificate highlights the fact that the individual adviser has adhered to the FSA APER and the CISI’s Code of Conduct In applying for an SPS, both members and non-members who are applying by virtue of being CISI Corporate Supporters’ staff will need to comply with the CISI Code The certificate highlights the fact that the individual adviser has maintained a log and recorded evidence of their continuing professional development The certificate highlights the fact the 12-month period for which the SPS is valid The certificate contains the individual adviser’s CISI membership number The certificate contains the date on which the individual adviser joined the CISI (if applicable) The certificate contains the individual adviser’s CISI membership grade (if applicable) The certificate is the property of the CISI and must be returned immediately if recalled See page 16 of RDR booklet
SPS Renewal Process • SPS requirements to be met: • Confirmation of adherence to APER • Confirmation of compliance with CISI Code of Conduct • 35 hours CPD compulsory • If adviser has added RDR specialist areas they would need to provide evidence of undertaking suitable qualification / gap-fill activities • Form available later in the year • Should be easier from HR / T&C / Compliance point of view
CISI Communication • CISI RDR booklet – April 2012 edition is the 6th in the series, any updates signalled through PDF versions • CISI CPD booklet – which includes specific RDR related guidance • The CISI website – RDR tab on homepage containing all relevant information • RDR newsletter – usually monthly • CISI visits from Customer Relationship Team to give advice and guidance to firms • A dedicated email address rdr@cisi.org