1. FAIS FIT & PROPER BEYOND 2009…
JANE APPASAMY

2. Road Map… Background and Context Going forward into 2010
Why it all began…
Where it all began…
How F & P has evolved…
Going forward into 2010
The “old” & the “new” 2004 vs 2008
Importance of “DOFA”
“Transitional” generation versus “non-transitional”
Competence focus

3. Why it all began?
Image of industry – tainted by unscrupulous/dishonest behaviour
Professionalizing industry meant qualifications, experience and accountability for staying current (like most other professions)
In order for Financial Planning seen as a serious career choice, had to have “serious” criteria…

4. Where it all began…
FAIS introduced into the financial services world…2004
Determination of Fit & Proper 2004
All the fuss was about Columns 1,2,3 and 4!!!
Concern at the time – meeting column 4 requirements
No CPD
No Regulatory Exams
No “transitional arrangements”
Just Financial soundness; Honesty & Integrity, Operational Ability, Competency (S.H.O.C.)

5. 2008 Fit & Proper requirements
HONESTY
& INTEGRITY
CPD
REPRESENTATIVE
COMPETENCE
EXPERIENCE
QUALIFICATONS
REGULATORY EXAMS
NEW
NEW

6. How Fit & Proper has evolved
BOARD NOTICES
103,104,105,106,
of 2008
DETERMINATION
OF FIT & PROPER
2004
Column 3 & 4 requirements
“Entry” & “deadline” requirements.
Qualifying criteria
Relates to knowledge & skill.
List of Recognised Qualif:
Content must satisfy the qualifying Criteria.

7. Date of first appointment
Critical to determine whether “transitional” or not
“Break” in service: take original date of appointment in industry

8. The ’04-’09 “transitional generation”
All representatives appointed between September 2004 and 31
December 2009 can be grouped into the following groupings:
CHOICE: credits/whole qual.
Group 1:
Appointed between
September 2004
& 31 December 2007
Group 2:
Appointed between
1 January 2008
& 31 December 2009
CREDITS:
31 DEC 09 DEADLINE
QUALIFICATION & RE:
2011 & 2013 DEADLINE

9. TRANSITIONAL versus “NON-TRANSITIONAL”
Appointed
Appointed
2008
Appointed
2009
BEYOND 2009…..
Appointed
2010 onwards…

10. Competence in more detail…
Experience;
Qualifications (qualifying criteria)
Regulatory Exams

11. Qualifications unpacked…
1. GENERIC – “G”
- Content generic
- Also complete product specific Regulatory Exams
2. SPECIFIC “S”
- 80% of contents specific
- If completed end 2009 exempted from product specific RE
- Falls away from Jan 2010

12. Qualifications unpacked…
3. SPECIFIC “SP”
- Match qualifying criteria 100% in terms of contents
- Exempted from product specific RE
- Applies only from 2010 onwards

13. Beyond 2010: ’04-’09 generation
Did not meet deadline of Dec 2009
No longer fit and proper
Remove from Representative Register
31 December 09 – debarment and must follow reinstatement process
E.g. 20 Dec 09 - remove with 3A, not debarment, no reinstatement necessary (1A)
FSP – competitors & non-advice positions
Awaiting clarity from FSB re requirements.
Reintegration to advice-giving position

14. The “2010 onwards generation”
Experience:
-Must be product specific
-Can be gained under supervision
-Depends on product subcategory
Qualification:
-Completed qualification
from list of recognised
qualifications appropriate
Can be obtained under
supervision
Regulatory Exam:
-Level 1 must be completed 2 yrs from appt.
-Level 2 within 6 yrs from date of first appt.
-May be completed whilst under supervision

15. Thank you…