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CACS Continuing Professional Development

(“CPD”)

For

Covered Persons under the

Private Banking Code of Conduct (“PB Code”)

Frequently Asked Questions (FAQs)

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CACS CPD FAQs

TABLE OF CONTENTS

SECTION (A) – GENERAL ........................................................................................................................ 3

SECTION (B) – CACS CPD OBLIGATION .................................................................................................. 4

SECTION (C) – RECOGNISED CACS CPD ACTIVITIES ............................................................................... 6

SECTION (D) – MONITORING CACS CPD HOURS ................................................................................... 9

SECTION (E) – PENALTY FOR NON-COMPLIANCE OF CACS CPD REQUIREMENTS .............................. 10

SECTION (F) – ABSENCE FROM SINGAPORE PRIVATE BANKING INDUSTRY ........................................ 11

SECTION (G) – REPORTING & SUBMISSION ........................................................................................ 12

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SECTION (A) – GENERAL

Q1. What is the role of the Private Banking Industry Group (“PBIG”)?

A1. The PBIG is mandated with the task to shape the development and foster the sustainable growth of the Singapore Private Banking Industry.

Q2. What is the role of the CACS CPD Advisory Group (“CPDAG”)?

A2. The CPDAG provides guidance on CACS CPD eligibility topics and recognized CACS CPD learning activities. It will not aim to endorse specific courses.

Q3. Who are the members of the CPDAG?

A3. The CPDAG consists of a committee of 10 representatives from Singapore’s Private Banking industry holding the positions of Head Relationship Manager (RM), Head of Product Specialist, Head of Compliance and Head of Human Resource (HR) or Learning & Development (L&D).

Q4. What is the role of the CACS Administrator (IBF)? A4. The CACS Administrator will be the first point of contact in administering the established CACS

CPD criteria and standards and handling all CACS CPD queries. Q5. What is the role of the Covered Entity’s Designated Representative(s)?

A5. The role of the Covered Entity’s Designated Representative(s) is to assess and certify CACS CPD training programs taken by their Covered Persons to ensure compliance with the CACS CPD guidelines as well as oversee the reporting of their Covered Persons’ CACS CPD status to IBF.

Q6. Who is eligible to be appointed as the Covered Entity’s Designated Representative(s)?

A6. The Covered Entity’s Designated Representative(s) shall be appointed by the Covered Entity’s Board or senior management. The Designated Representatives shall have managerial oversight in areas such as Human Resource (HR), Learning & Development (L&D), Compliance or in managing Covered Persons.

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SECTION (B) – CACS CPD OBLIGATION

Q7. With the launch of the PB Code, when will a Covered Person be required to commence his CACS CPD obligation?

A7. With the launch of the PB Code, a Covered Person will be required to fulfill his CACS CPD obligation with effect from 1 March 2013. The CACS CPD calendar year commences on 1 January and ends on 31 December every year.

If a Covered Person passed his CACS prior to 1 March 2013, his CACS CPD obligation under the PB Code for Year 2013 is 12 hours of CACS CPD. His CACS CPD obligation from Year 2014 onwards is 15 hours of CACS CPD per year.

If a Covered Person passes his CACS Assessment on or after 1 March 2013, his CACS CPD obligation in the year which he passes his CACS Assessment, will be pro-rated as set out in paragraph 3.1.3 under the Competency Section of the PB Code as follows:

(a) Less than 3 months – 5 CACS CPD hours

(b) Between 3 months to 6 months – 8 CACS CPD hours

(c) Between 6 months to 12 months – 12 CACS CPD hours

From the following year onwards, his CACS CPD obligation is 15 CACS CPD hours per year.

Q8. Can the CACS CPD activities that a Covered Person undertakes between 1 Jan 2013 and 1 Mar 2013 qualify for the CACS CPD obligation under the PB Code?

A8. CACS CPD activities undertaken between 1 Jan 2013 and 1 Mar 2013 can be counted towards fulfilling 2013’s CACS CPD obligation provided the activities were undertaken after the Covered Person passed his CACS Assessment.

Q9. Can the CACS CPD activities undertaken before the Covered Person passes his CACS Assessment qualify for the CACS CPD obligation under the PB Code?

A9. No, CACS CPD activities undertaken prior to passing CACS will not count towards meeting his CACS CPD obligation.

Q10. Can a Covered Person carry 'surplus' CACS CPD hours from one year to the next?

A10. No. ‘Surplus’ CACS CPD hours cannot be carried to the next year.

Q11. Will an overseas private banker who is temporarily transferred to Singapore’s branch be

subject to the CACS CPD requirement?

A11. If the temporarily transferred overseas private banker is required to take the CACS Assessment,

he is obligated to fulfill his CACS CPD requirement as well during the period for which he is

working in Singapore.

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Q12. If a Covered Person has been exempted from taking the CACS Assessment (either having undergone NEC or FICS certification), does he still need to fulfill CACS CPD obligation?

A12. Yes, all Covered Persons are required to fulfill their CACS CPD obligation under the PB Code, which will take effect from 1 March 2013.

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SECTION (C) – RECOGNISED CACS CPD ACTIVITIES

Q13. How can a Covered Person find out if an activity or program is CACS CPD recognised?

A13. The Covered Person should approach his Covered Entity’s Designated Representative(s) for all matters pertaining to his CACS CPD requirements.

Q14. Why is there a cap on the maximum number of hours that can be attained from a CACS CPD

activity?

A14. The maximum cap of 10 CACS CPD hours for each category of activity is intended to ensure that

the Covered Person benefits from a more comprehensive range of learning platforms to

enhance his professional development.

Q15. If the E-learning program is under 30 minutes, will it be counted towards CACS CPD hours?

A15. No, an e-learning program should have a recommended learning hour of at least 30 minutes to

be considered towards CACS CPD hours. The e-learning program should also include an

assessment component to be eligible for CACS CPD hours.

Q16. Which FICS-accredited programs will qualify towards the fulfillment of CACS CPD

requirement?

A16. All FICS-accredited programs will qualify towards the fulfillment of CACS CPD requirement

(subject to the relevant cap).

Q17. Does a Covered Person receive CACS CPD hours by attending company meetings?

A17. No, CACS CPD hours will not be awarded to attendance of company meetings.

Q18. Is internal training conducted by the Compliance department recognised as CACS CPD hours? A18. As a guiding principle, for internal trainings to be recognised as CACS CPD hours, the knowledge/

skills acquired have to be transferable within the industry. For example, while bank-specific compliance training should not be recognised, general compliance training in the areas of rules and regulation and market conduct can be recognised.

Q19. Can internal briefing sessions be recognised as CACS CPD hours? A19. Internal briefings (eg. regular briefings on investment outlook / economic updates or analyst

briefings on “house views” etc.) should not be recognised as CACS CPD hours as these are part of the Covered Person’s work and do not contribute to his professional development.

Q20. Is there a minimum criterion for trainers of internal or external courses recognised for CACS

CPD?

A20. Trainers should minimally possess the relevant qualification or experience in the subject matter.

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Q21. A Covered Person spends hours each day reading newspapers, journals, research papers etc. What CACS CPD hours does he get?

A21. Reading of newspapers, journals and research papers will not qualify for CACS CPD hours.

Q22. For finance related undergraduate programs, MBA programs and CFA program coursework, is

there a maximum number of CACS CPD hours granted per activity?

A22. A maximum of 10 hours a year will be granted, without CACS CPD hours being carried forward.

Candidates should retain copies of certificates / examination results as supporting evidence.

CACS CPD hours can only be granted upon passing the program.

Q23. Can time spent on preparing for an examination be recognised as CACS CPD hours? A23. As a guiding principle, activities should be measurable and verifiable to be recognised as CACS

CPD hours. For example, a preparatory course which is verifiable and measurable, leading to a pass in the examination, could be recognised.

Q24. Can time spent on preparing for an instruction activity be recognised for CACS CPD hours? A24. As a guiding principle, activities should be measurable and verifiable to be considered eligible

CACS CPD activities. If the time spent on preparing for the instruction activity can be measured and verified with supporting documents, it can be recognised as CACS CPD hours.

Q25. Can time spent on writing internal research reports be recognised as CACS CPD hours under

the Research and Publication category? A25. Internal research reports (eg. reports / research prepared for internal briefings or for

dissemination to clients / investors) should not be recognised as CACS CPD hours as this is part of the Covered Person’s work and does not contribute to his professional development. Exception is only made for reports that are published or disseminated to the public.

Q26. What is considered a recognized Committee and/or Industry Working Group?

A26. Financial sector related industry committee of professional bodies, industry associations, IBF or

MAS will be considered recognized industry committee for purpose of fulfillment of CACS CPD

hours.

Q27. How does a Covered Person show evidence of participation in leadership activity?

A27. Covered Person who is a member of an industry committee is to produce a certificate of

attendance from the Secretariat of the committee to reflect the appropriate hours of his

involvement.

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Q28. Having passed the CACS Assessment, a Covered Person goes on to complete a FICS-accredited program in Wealth Management - Relationship Management (High Net Worth) at Job Role IV and above and attains FICS Certification. How will this count towards the fulfillment of CACS CPD requirement? A28. As long as the Covered Person completes the FICS-accredited programme in Wealth Management - Relationship Management (High Net Worth) at job role IV and above after passing the CACS assessment, and attains FICS certification, he will be deemed to have fulfilled CACS CPD requirements for 2 years – the year in which he completed the program and the year in which he attained FICS certification (Note: this may include the year after certification if program completion and attainment of certification took place in the same year). In the case where the Covered Person completed the FICS-accredited programme in Wealth Management - Relationship Management (High Net Worth) programme at Job Role IV and above and attained FICS certification between 1st Sep 2011 (CACS commencement) and 1st Mar 2013, he would be deemed to have fulfilled CACS CPD requirement for the years 2013 and 2014. Q29. If a Covered Person had completed the FICS-accredited programme in Wealth Management - Relationship Management (High Net Worth) programme at Job Role IV and above and attained FICS certification prior to 1st Sep 2011 (CACS commencement), would he be deemed to have fulfilled CACS CPD requirement? A29. No, he may not use the completion of the above programme and certification attained before 1st Sep (CACS commencement) to fulfill CACS CPD requirements.

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SECTION (D) – MONITORING CACS CPD HOURS

Q30. Whose responsibility is it to monitor the Covered Person’s CACS CPD requirements?

A30. Both Covered Entities and Covered Persons will have to maintain records of how the expected

CACS CPD hours are met. Covered Entities are required to monitor and ensure that all Covered

Persons who act on their behalf will meet the expected CACS CPD hours by the end of each

calendar year. (See paragraphs 3.1.7 - 3.1.9 of the PB Code)

In the event that the Covered Person leaves Covered Entity X to join Covered Entity Y, X will

have a responsibility to issue a confirmation of the Covered Person’s CACS CPD records before

he leaves. It is Y’s responsibility to ensure that the Covered Person fulfills his outstanding CPD

obligation for the year.

Q31. Is there a specific format for the bank to adhere to when issuing the confirmation letter of the

Covered Person’s CACS CPD records?

A31. A sample template (Annex 2C) is available on the IBF website. However, if a bank already has a

CPD system with tracking capability, the bank may provide the confirmation letter using its

own format.

Q32. What are the supporting documents required for an activity under the Training & Education

Category to be considered verifiable?

A32. Supporting documents may include the employer’s acknowledgement or sign-off, certificate of

attendance or completion, or where there has been an assessment, a copy of the result slip.

Q33. How long does a Covered Person need to retain the supporting documents for CACS CPD

activities?

A33. All CACS CPD supporting documents should be retained for a minimum period of 3 years for

audit purposes.

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SECTION (E) – PENALTY FOR NON-COMPLIANCE OF CACS CPD REQUIREMENTS

Q34. What will the consequences be if a Covered Person is unable to fulfil the CACS CPD

requirement by 31 Dec of any given calendar year?

A34. If a Covered Person is unable to fulfil the CACS CPD requirement by 31 Dec of any given calendar

year, he will be required to make up the remaining CACS CPD hours in the following calendar

year, plus a 3 CACS CPD hours penalty. This implies that, in addition to the usual 15 CACS CPD

hours, he will be required to make up the remaining CACS CPD Hours of the previous year plus a

3 CACS CPD hours penalty.

Illustration of Penalty for Non-Compliance of CACS CPD requirement

Q35. What will the consequences be if a Covered Person is unable to complete the CACS CPD

requirement for 2 consecutive years?

A35. If a Covered Person is unable to complete the CACS CPD requirement for 2 consecutive years, he

will be required to re-take and pass the CACS Assessment. According to the PB Code, the

Covered Person will not be able to practice during the lapse period.

Q36. If a Covered Entity hires a Covered Person with penalty hours brought over from the previous

year, is it the responsibility of the Covered Entity to ensure that the Covered Person fulfills his

uncompleted and penalty hours brought over?

A36. Yes. The new employer is responsible for ensuring that the Covered Person fulfills his

uncompleted and penalty brought over from the previous year(s) in addition to his CACS CPD

obligation for the year.

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SECTION (F) – ABSENCE FROM SINGAPORE PRIVATE BANKING INDUSTRY

Q37. Can an overseas course count towards fulfilling CACS CPD requirement?

A37. Yes. Courses which fall within the CACS CPD requirements whether taken locally or overseas will count towards CACS CPD hours. Please ensure you have a copy of all the relevant documents.

Q38. If a Covered Person left the private banking industry but is planning to rejoin the industry,

what is his CACS CPD obligation?

A38. As long as the Covered Person is in a client-facing advisory role in a Singapore-based Covered

Entity, he is required to fulfill CACS CPD obligation. Whenever he exits the industry, the

obligation does not follow. When he rejoins the industry, he will have to resume his CACS CPD

obligation.

In addition, if he is away for more than 3 years, his CACS assessment will be nullified and he will

need to re-take the CACS assessment. His CACS CPD obligation will then resume after he passes

his CACS assessment.

However, we make exceptions for Covered Person who continue to be in a client-facing advisory

role working overseas. For such instances, Covered Person will not need to re-take his CACS

assessment, even if he is away for more than 3 years.

Q39. Would Covered Persons who are on extended leave of absence eg. maternity, prolonged

medical leave, sabbatical etc, be subjected to fulfilling the CACS CPD requirement during

their absence?

A39. Covered Persons who are on extended leave of absence would have his CACS CPD requirement

pro-rated accordingly for the calendar year(s) in which he was absent. However, if Covered Person is away for more than 3 years, CACS assessment will be nullified and he would need to re-take the CACS assessment before returning to a client-facing role as a Covered Person.

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SECTION (G) – REPORTING & SUBMISSION

Q40. Does a Covered Person or the Covered Entity report the status of their CACS CPD hours to the CACS Administrator (“IBF”)? How frequently should this report be submitted?

A40. The Covered Entity’s Designated Representatives are expected to submit CACS CPD reporting of

their Covered Persons annually for the calendar year, using the form - “Annual fulfillment of CACS CPD requirements (Annex 2a)” and “CACS CPD Programmes (Annex 2b)”, by 31st January of the following year.

Q41. What will happen after the Covered Entity submits their Covered Persons’ declared CACS CPD

hours to IBF?

A41. As the CACS Administrator, IBF will be compiling statistics and making regular reports on the

CACS CPD status of the Covered Entities and their Covered Persons as well as the progress of

CACS to the regulatory authority (i.e. Monetary Authority of Singapore and the Private Banking

Industry Group Executive Committee).