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Wait for exam clarity and you may regret it

by William Robins on Sep 16, 2010 at 08:28

Wait for exam clarity and you may regret it

The Financial Services Authority’s ‘no regrets’ policy is in danger of becoming deeply ironic unless the regulator and the Financial Services Skills Council (FSSC) act quickly to confirm gap-filling criteria.

Advisers were told last year they could use continuous professional development (CPD) to top up incomplete level four qualifications instead of having to take the new exam. However, they still don’t know how much the exams they have passed will count towards their final level of qualification. Nor is it certain whether existing CPD will meet the regulator’s learning objectives.

To qualify under the no regrets policy, advisers must trace their entire exam and CPD records to determine which gaps need filling. This will take months and has to be independently verified by the FSA.

No regrets is measured against the syllabus, so even if the exam questions appear to fit the bill, the qualification may still not make the grade.

Add to this the elusive ethics module. No final details have been forthcoming from the FSSC or exam bodies on when advisers will be able to complete modules for this gap.

The first task for advisers is to find the old syllabuses and exam papers to see if they fit the FSA’s no regrets framework. That won’t be easy – or free. The Chartered Insurance Institute charges for both.

Advisers were not told until June 2009 that they could use records dating back several years, so there’s a good chance their records are lost or insufficiently complete to satisfy the FSA.

It could be June 2011 before all these issues are resolved, leaving 18 months for advisers to catch up on their remaining CPD gaps. If they have run out of time, they will still have to sit an exam.

Exams, qualifications and the constant shifting and updating of standards have been a fact of life for diligent advisers for several years. This makes the issue all the more tiresome.

There are well-qualified, chartered and certified advisers who, this close to retail distribution review implementation, are still being put in an awkward position by the FSA.

Unless advisers want to bet on a quick and decisive answer from the FSA, they had better start digging out the old CPD files.

29 comments so far. Why not have your say?

Anonymous 1 needed this 'off the record'

Sep 16, 2010 at 08:48

Just put the qualifications back one year - easy. Dont make fools of themselves again.

the FSA has no right at all to place so many people under such stress. The country has been through a major recession, unions are threatening to take us right back in, the industry is struggling anyhow and a few incompetents at the FSA cant even finalise something they have been working on for years when that is all they have to do.

They only have to come up with the final details, the people in the industry have to work, hit targets to exist and retain employment, keep their private lives intact and find in addition 100s of hours of study time in an ever decreasing timeframe, yet still dont fully know what they should be studying.

When you mess things up you should put your hands up and move the timetable, the FSA is not here to destroy an industry it is here to regulate it, start doing something right for once.

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David Ross

Sep 16, 2010 at 11:02

I do wish people would take the time to check their facts...

The CII or PFS does not charge for access to past syllabuses. The more recent syllabuses are available online and you can download them. and we are currrently in the process of uploading the older ones to our website - this should be done by the end of the month. They will be available to anyone at no charge.

PFS or CII members can access a free gap fill tool that will assist them identify want gaps need completing and what CPD (if any) they need to undertake. Any subsequent CPD will be offered free to members.

Most existing advisers with a level 4 qualification can expect to do very little to ‘top up’ their existing qualification and become RDR compliant. It could be as little as reading a textbook for example. When trying to fill your gap you can include historic CPD so again if you've been keeping up to speed on things like ethics

Stories such as this serve only to create divison and confusion amongst the adviser community and I would recommend that anyone who is unclear as to what is expected of them ignores the media and approachs either their professional body, their trade body or the FSA directly. The gap fill elements of the RDR should not be something to cause undue concern to adcisers and I would caution anyone from being fearful without having first undertoodexactly what will beexpected of them between now and the end of 2012.

If you want copies of past CII syllabuses go here:

http://www.cii.co.uk/financialservices/qualifications/Qualification.aspx?award=CertFP&endstem=1§=273

David Ross

CII

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Colin Barrett

Sep 16, 2010 at 11:16

Hi David

Thanks for those clarifying points. I've been watching for a while to see when the CII gapfill tool comes back on line. Would you be able to give us an update on that?

Appreciate that you've been bashed around on here in the past, regardless of the rights and wrongs of various arguments I'd like to register that it is really useful to have someone from the CII who's happy to participate in these forums, using their own name and giving honest answers without all the usual "corporate speak".

Colin

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Trevor Brookes

Sep 16, 2010 at 11:35

I am worried about your well being Anonymous One. I think you need a holiday.

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David Ross

Sep 16, 2010 at 11:36

Colin,

Thank you for your supportive comments. A rare but welcome sight on here...

The gap fill tool should be up in the next few days. We contiune to update and amend elements in response to feedback from members.

It will evolve over time but there is an obvious need for clarity now. So if only to combat the wealth of disinformation knocking around at the moment we are keen to get it back online.

I would reassure your and your peers that the issue of gap fill is not something that should cause undue concern. If you are facing a gap it is because you already have a QCF level 4 qualification and the variation between what you know and what the FSA want you know by December 2012 is likely to be quite small. It will vary between individual (hence the need for the tool) but when you take into consideration the CPD you have already done any shortfall should be minimal.

David Ross

CII

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David Ross

Sep 16, 2010 at 11:48

Anon 1,

The PFS or any of the trade bodies or other professional bodies should be able to give you a clear idea as to what you need to do to reach the qualifications threshold laid down by the FSA.

I would encourage you to tallk with one of these bodies. Depending in your existing qualifications it may be a significantly smaller challenge than you think and there is plenty of support out there to help you get through the RDR.

David Ross

CII

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Martin Bamford

Sep 16, 2010 at 12:02

This is an important debate, and it is good to see the information from David at the CII here - your input is much appreciated, David.

We started to discuss this subject at the Surrey IFP meeting the other evening. Apart from a few individuals, nobody in the room had read CP10/14. This is a good place to start if you want to understand these requirements.

As a Chartered Financial Planner and CFP, I accept that I will need to do some 'gap filling' or pass a few 'new' level 4 exams to meet the qualification requirements by 31st December 2012. Put simply, by tested knowledge is out of date now and needs to be updated. In fact, I have already started studying for the CII R01 Regulation & Ethics paper, as there are areas of this I have never been tested on before.

I think there is still some confusion about the nature of 'gap filling' through CPD. It has been suggested to me that any CPD used for this purpose will need to be 'structured'; I understand this to mean signed off formally by an accredited professional body.

It is good to hear David from the CII promising that the CII will be offering this structured CPD for gap filling free of charge to members.

The likely timescales involved in all of this are slightly worrying. Assuming it takes until next June for the FSA to accredit professional bodies, this leaves around 18 months for IFAs to get any old CPD records assessed, identify any remaining gaps and then 'fill' these gaps with structured CPD.

18 months to do all of this sounds tight but reasonable, if you are already at Level 4 by next June with some gaps to fill. What about those IFAs who are still studying to reach Level 4 by the end of 2012, and will also have gaps to fill through structured CPD by this deadline, once they have passed their exams?

I look forward to seeing the CII Gap Fill analysis tool back online later this week and hope it produces slightly less worrying results for me than it did when I managed to use it the first time!!

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Duncan Carter

Sep 16, 2010 at 12:34

It is good to see David Ross's comments and I think the CII is moving in the right direction. The issuing of free past papers is a welcome development as I have spent a fair bit on buying them in the past and have felt a bit cheated given that I pay sub's, exam fees, and for course books etc. So well done on this.

To go back to the main point of the article however, the FSA really does need to step up to the plate. It has created the timescale but not the requirement and that is not really professionally acceptable. It doesn't send out the right signal in the same way as the issue over what was the appropriate level 4 seemed equally confused.

Having achieved Chartered and FPFS status, I'd like to think I don't need to do more exams to prove compliance but if say doing R01 as Martin is doing, provides a means of gap filling is what's needed then I'd just really like someone to make the decision. I believe there is a significant credibility issue at stake here.

Likewise the Gap analysis tool, it's been off line for quite a while and at our regional PFS conference on Tuesday we were told it would be available as from yesterday but it's still not there. Maybe a bit of under promising and over delivering would be a good idea.

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Ian Mundy

Sep 16, 2010 at 13:03

The handling of this situation by the CII has been nothing less than appalling.

From their website I registered to receive an e-mail when the top up/gap-fill too was available. Nothing has been forthcoming !!

Previous infomation led me to look at a website ending in 'top-up'. This said that the top-up tool would be available at the end of June !

I have now checked again and their is now a website address ending in 'gap-fill'. Since I have found this a couple of weeks ago it has only ever been off-line.

I would have registered to do the R01 exam weeks ago if I had known there was going to be this much confusion !!

This needs to resolved by the CII at the earliest possible time and apologies given for the mess.

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David Ross

Sep 16, 2010 at 14:20

Ian Mundy,

The reason you haven't received an email from the CII is because we haven't formally launched theCPD tool to all our members. The pilot prompted some valuable feedback and we have been incorporating this ahead of a wider roll out to members..

Whilst I understand your desire for answers you there seems little point in launching something hald baked. It's worth considering the size of the task facing the CII - we are looking at mapping individual qualifications records from as far back as the 1980's. These are on micro fiche and need to be manually mapped against the new FSA standards. As you will appreciate this is extremely resource intensive. At the same time we are developing a suitable CPD programme, launching a new suite of examinations (R0) and piloting an alternative assessment proposition.

Please be assured we are working tirelessly to ensure that our members get as much support as we can offer. But it needs to be accurate, use-friendly and genuinely of value. The Gap fill tool should be online again within the next few days. It wil evolve over the coming months but it should offer some reassurances about what you need do to satisfy the FSA.

David Ross

CII

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Tim Page

Sep 16, 2010 at 14:29

The CII have started to move in the right direction. Their commitment to supply past syllabi is only a week old and very welcome. I understand this will be done in "the next week or so". Let's hope this doesn't take as long as the gap-tool...

The big problem I have is that CII say gap-filling will not be very onerous and we should all calm down. But that's not what the FSA have said in CP09/31 and reiterated in CP10/14.

Specifically qualification gap-filling will have to be evidenced by a document that confirms:

■That structured learning was completed.

■The learning outcome covered

■The result of the assessment

■The name of the independent assessor.

It is the requirement for an independent assessment that means most CPD done by advisers in the past will not qualify.

If the FSA have changed their stance they need to make this clear now for those of us trying to make decisions on the right way to go.

To be fair to the CII, have they received an unfair amount of kicking over the content of the RDR-ready dipoma. As David Ross has rightly said on this blog and elsewhere, this was done by the FSSC in consultation with the industry. If you didn't reply to the consultation you can't complain.

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Tim Page

Sep 16, 2010 at 14:31

For more information you can go to: http://www.pagerussell.co.uk/no-regrets/

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David Ross

Sep 16, 2010 at 14:33

Martin,

The PFS Board ( made up primarily of IFA's) are currently reviewing the content of the Gap Fill Tool website. Assuming they are comfortable with what we are proposing the tool will be back up and running within the next few days.

There is clearly some confusion (and concern) around this issue. and I hope the gap fill tool will offer some much needed clarity and reassurance.

I would encourage those advisers who are not PFS or CII Members to seek answers from their professional body, their trade body or the FSA. There is a great deal of noise around this topic that is ill-informed and I would not wish advisers to worry unduly about gap fill.

David Ross

CII

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Tim Page

Sep 16, 2010 at 14:50

There you go again David, telling us all to calm down like good compliant little boys and accept the CII solution.

Either:

1) the CII does not fully understand the FSA's requirements for qualification gap-filling or

2) you've been tipped the wink from the FSA that they will relax their requirements.

If 2) then the FSA needs to issue clarification ASAP. If 1) it is you that needs to check your facts and stop being so patronising.

I hope the answer is 2).

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Martin Bamford

Sep 16, 2010 at 14:54

Thanks, David.

Can you confirm your (the CII's) understanding of what will be required for CPD to be used to 'gap fill'? As Tim Page has described above, my understanding is that 'structured' CPD will require individual assessment.

Knowing the gaps you need to fill is one thing. I suggest that the (much) bigger issue here is the ability to actually fill them.

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David Ross

Sep 16, 2010 at 15:05

Tim,

A fair challenge.

Optimistically (some might say naively) I believe the FSA is likely to take a less prescribed view of verification. But, and a crucial but, this is for the FSA to tell the market once the current consultation (CP10\14) has closed. I would suggest advisers voice their concerns directly to the FSA or via their representive trade bodies. Our view is that theFSA shouldn't expect advisers to rummage through old shoeboxes looking for receipts that prove they attended a CPD event in 2006 just so they could evidence their gap fill. Fingers crossed common sense prevails.

What I would say is that from the mapping we have undertaken the gaps between what advisers have done and what they need to know by December 2012 seem relatively small. Clearly I can only speak for PFS members but if this is mirrored across the wider market then advisers would seem to have done much of what is needed of them. I accept that the issue of verification remains outstanding and still the subject of an FSA consultation but once you establish you have a small gap it may just be straight forward enough to simply attend a CPD event and have done with it.

David Ross

CII

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David Ross

Sep 16, 2010 at 15:19

Martin,

On the face of it advisers could fill their gap by going to events, reading textbooks, attending courses, completing online CPD modules etc.

Exams can help plug the gap but they aren't really necessary. If you can't parallel park a car you could go back and learn to drive all over again then re-sit your driving test OR you could just have someone teach you to parallel park. Both will solve the problem but the first solution is obviously more expensive and more costly.

One area that crops frequently is ethics. Doing an online CPD module on ethics would seem to meet the FSA requirements and would enable an adviser to tick that off. If that's your only gap and assuming the CPD is suitable then you're RDR compliant.

David Ross

CII

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David Ross

Sep 16, 2010 at 15:24

Tim - Apologies if I come acrosss as patronising it is certainly not my intention. I appreciate you are up to speed on much of this but you will understand that in an open forum I tend to labour certain points for the benefit of other readers.

Other readers - Sorry if I am being patrionising. I am genuinely trying to be as clear and concise as I can be on asubject that is both hugely complex and emotive.

Martin - apologies for the repeated use of flimsy analogies to try and get a point across. It's just how I explain things.

David Ross

CII

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Martin Bamford

Sep 16, 2010 at 15:45

Thanks, David.

It will be interesting to see the gap fill analysis tool once it goes live again. You are very welcome to publish my own gap fill results here if you like, as an example of how they will appear for a member when the tool goes live.

Regards,

Martin

PS - don't worry about the flimsy analogies; compared to the ones I tend to use, they're not that bad!

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Tim Page

Sep 16, 2010 at 16:10

David,

I take your point on verficiation. But verification is not assessement and the FSA is asking for both. (Unless you know soomething we don't).

Tim

PS: I do hope your optimisitc view is correct. But I can't make business decisions based on the optimistic view of the CII Director of Communications. I can only act on of FSA documents.

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David Ross

Sep 16, 2010 at 16:36

Tim,

Our response to the latest FSA consultation paper is being formulated and I'd be happy to share this with you once it's finalised so you can see how our concerns overlap with yours, most notably around the need to clarify specific terms, processes and timescales.

David Ross

CII

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Mark Thewlis

Sep 16, 2010 at 19:11

What would be incredibly helpful is for the CII diagnostic tool to anaylsis the gaps in advisers potential qualifications BEFORE they selected the exam unit.

At the moment the analysis is on what you already have. But if you could input your proposed study route people could make more informed choices about which exam to take. Clearly there will be advantages & disadvantages of each option but without this vital information that will be hard to quantify.

Advisers & industry professions are currently planning their study route blindfolded (unless they choose all the RO exams). The tool only really works at the moment if you have level 4 or 6. Its use for anybody else is some what limited.

I hope this development comes quickly.

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Anonymous 1 needed this 'off the record'

Sep 17, 2010 at 09:24

re Trevor Brookes - me AFTER a holiday, thank you for your concern.

Also it is good to hear Martin Bamford also mention the timeframe even with his level of qualifications.

I actually do not always refer to myself in my comments.

The timeframe is far to tight even for people who have everything perfect in their working and private lives, they are in danger of neglecting a client in all of this confusion. It is unprofessional.

The stress created in the likes of the CII of finalised information which then they turn in to study material then put in to print and distribute can only be imagined.

However advisers who are in a good position should think back to their working collegues over the years who have had difficult periods in their lives, their own health, health of family members, their relationships, finances, children issues or simply demands on them at their current stage of life.

It is totally unacceptable to place this pressue in such a constrained time frame on human beings.

Had I still been in my previous outside industry role I could not place this type of pressure on staff without running the serious risk of creating a compensation claim against the group, let alone with the potential prospect at the end of any of the staff losing their incomes.

It is nothing short of a disgrace and seriously unprofessional, it also demonstrates the organisational skills of the regulator who is granted charge of our industry. Diabolical.

The clock has ticked too much.

If anyone's life crumbles I hope they can uphold a claim on the FSA, I will gratefully pay the extra premium if this happens to them.

I do not blame the CII or any other organisation, until they received the baton they could not run with it, they must be allowed time to transfer the information in to action and shouldnt carry the blame of the FSA and FSCC.

Just move this part of the RDR back from the delay from March 2010 to implementation, simple. Something intelligent done for a change.

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Tim Page

Sep 17, 2010 at 09:44

@ Anonymous 1: Yes it is tough trying to get this all done in time. Which is why I highlighted this particular issue now, whilst there's time to get it sorted.

To be fair, the FSA are now switching their attention to the progress of the providers and advisers firms in getting ready for RDR. Let's hope they do something concrete to help.

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David Ross

Sep 17, 2010 at 10:48

Mark Thewlis,

If you have some existing qualifications then I'd recommend calling our contact centre and talking to one of our advisers. They can take you through your options. They will need to understand what qualifications you've done so far and will establish what is best for you, taking into account any specialisms you have, or wish to develop, whether you see yourself stopping at level 4 or progressing onto Chartered. They will also discuss your preferred style of study, how you manage your time and how you prefer to be tested. You could find that because of your existing qualifications you need only do two or three additional exam units and a bit of CPD to get to the new FSA benchmark rather than sit a whole qualification but this varies from adviser to adviser.

Our advisers are trained to guide you through this complexity and from your posting I'd suggest it would be worth spending some time talking through your options. Clearly, I would not be playing fair if I did not mention that there are other bodies offering exams so you may also wish to talk with them.

David Ross

CII

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Anonymous 1 needed this 'off the record'

Sep 17, 2010 at 16:19

Interesting comment in one of our trade papers today, the paper highlighted the lack of qualifications in the FSA through freedom of information, very few are qualified above our entry exams, some not even to those.

Their comment was our staff do not need them they are not advisers.

Really?

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Phil Newton

Sep 24, 2010 at 14:43

I've read David Ross's comments with interest and thank him for taking the time to respond. However, having downloaded my own gap-fill report I am even more worried than before. I am Chartered and also hold the IFP's CFP qualification (both awarded in 2009 so they are not old versions) and yet I score only 82/132 points. It would appear that the CII takes no account of AF5 or the CFP or indeed other higher level exam passes (AF2 in particular). They simply don't feature in the mapping. One result of these ommissions is that in the 'Advice process' element of the tool I score an impressive 1/7. Given that I already hold what I believed to be the highest qualifications in this area, I am left wondering what I need to do to address that gap. The simple answer I think is to take more exams, as I doubt any amount of CPD would be sufficient to address an entire subject. But is that really right or fair?. As for talking to the CII, I've had two attempts so far and have yet to receive a reason why the advanced papers are being ignored. Any ideas David?

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David Ross

Sep 24, 2010 at 16:39

Phil,

CFP - unless you’ve used your IFP qualifications to gain exemptions from specific CII units we won’t know you have it so we can’t map it across. You’d have to map the learning points from the syllabus into the gap fill tool yourself.

AF5 is the application of the culmination of lots of knowledge but in itself doesn’t match any actual gaps identified by the FSA. Of course to pass AF5 you’ll need to know lots about pensions, investments, protection, tax, etc but the knowledge is proven in the other lower level units that you would have taken - J0 / FA, CF units. Same goes for H25 (AF5’s older brother).

AF1 covers 91% (16) of the tax gaps

AF2 covers nothing because its business financial planning and the FSA has stated that the RDR is personal financial planning.

AF3 covers 79% (15) of the pensions gaps

AF4 covers 85% (40) of the investment subject gaps

However I would point out that there is no reason to do more exams. It is important to understand what is expected of you in filling the gaps. We’re currently going through and creating / matching CPD to each of the gaps now and the most arduous requires that you read the equivalent of a single chapter of one book i.e. 15 pages. Most of the gaps can be filled by reading a page or two. Nothing seems particularly time consuming and as we’ve previously stated any CPD is free to members.

David Ross

CII

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Phil Newton

Sep 24, 2010 at 16:59

Thanks very much David for the clarification. I accept what you say about the AF exams, although I'm not sure about the AF5 as one of my biggest gaps is in the 'applying the investment advice process', which is about application of knowledge and skills rather than learning. If AF5 or the CFP don't get you credit for that part of the process then I'm not sure what would.

Your latter comments certainly have helped to put my mind at rest though, especially if you are saying that the CII will actually tell us exactly what we need to do. My real concern was that we would have to go about organising our own CPD, hoping that what we did would match the gaps and then submit it for testing at the end, only to be told that what we had done wasn't acceptable, thus wasting a lot of potential exam time.

Thanks again.

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