cisi.org The Retail Distribution Review 2012

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 Online form available in June 2012

SPS Application Fees PCIAM Application Type Initial 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 - er/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 December 2012 Between 1 July 2009 – 1 January July 2013 After 1 January months after you begin giving advice under supervision

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 already integrated 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 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:

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

Examples of Good and Bad Evidence

Outcomes of the Audit

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 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 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 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

CPD with CISI

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 address

Any Questions?