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 ProcessAll 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
Application TypeInitial
Application Price
Renewal Application
Price
Member – paying for SPS in advance with membership subscriptions prior to submission (or for initial applications during the pilot period ending 31 March 2012)
£35 (+VAT)
£20 (+VAT)
Member - paying for SPS at application £45 (+VAT)
£30 (+VAT)
Non-Member who is an Employee of Corporate Supporter £125 (+VAT)
£100 (+ VAT)
Advisers need to complete their personal details in this
section
Advisers need to confirm their RDR specialist area here
Advisers need to confirm their firm name here
Advisers need to confirm their SPS date here
Advisers need to confirm their Individual FSA number here
Advisers can obtain their Individual FSA number from
the FSA website - http://www.fsa.gov.uk/registe
r/indivSearchForm.do
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
3,664
Affiliates
829
MCSI
Affiliates
847
7,480
SPS – Application Problems
Gap-fill not completed fully or at all
Application made outside of CPD 3 month window
Some criteria not confirmed
Verifiers not confirming all fields
Declaration not confirmed
Firm FSA number entered by mistake (individual FSA number should be used, eg, ABC12345)
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
Adviser Assessed as Competent
Deadline for SPS
As at 30 June 2009 31 December 2012
Between 1 July 2009 – 1 January 2011
1 July 2013
After 1 January 2011 30 months after you begin giving advice under supervision
Qualifications and Gap-fillGap-fill is used to ‘top-up’ legacy or appropriate qualifications that existed prior to RDR and is a ‘once only’ activityGap-fill can be undertaken at anytime, not just after the examsFSA provided templates, CISI has pre-filled these, only for CISI and LSE qualifications on the websiteGap-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 advisersCISI will recognise gap-fill from other Accredited Bodies
Continuing Professional Development & SPS
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)
All CPD:
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 Process - SanctionsThe 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
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
Are there any waivers?
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 maintained a log and recorded
evidence of their continuing professional development
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 the 12-month
period for which the SPS is valid
The certificate contains the date on which the individual
adviser joined the CISI (if applicable)
The certificate is the property of the CISI and must be returned immediately if
recalled
The certificate contains the individual adviser’s CISI membership grade (if
applicable)
The certificate contains the individual adviser’s CISI membership number
See page 16 of RDR booklet
SPS Renewal ProcessSPS 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 [email protected]