You’ve done your CPD, but are you competent?
Since the FCA Retail Distribution Review (RDR), investment advisers must complete 35 hours of continued professional development (CPD) each year to ensure they keep up with the changes to markets, taxation and regulation.  Proof that this CPD has been undertaken is necessary for advisers to apply for their Statement of Professional Standing (SPS) each year, without which they cannot continue to give advice.

However, there is a difference between continued professional development and demonstrating competency, and it is the latter that has everyone talking.

The FCA Handbook states about maintaining competency, “A firm must review on a regular and frequent basis employees’ competence and take appropriate action to ensure they remain competent for their role.” This is not the same as CPD; an adviser can prove they have carried out at least 35 hours of ‘professional development’ but that does not mean they (still) possess the knowledge and skills necessary to deem them ‘competent’.

The regulator has said it believes that having a good level of knowledge is the foundation to giving sound advice, but how a firm regularly reviews its employees’ competence is open to interpretation. Firms currently have the flexibility to achieve this by whatever means it sees fit, such as product-based testing, diploma exam-based testing, and other in-house training and testing exercises, including role plays, or by paying for reassessment by examining bodies.

As all advisers must be Level 4 qualified, it stands to reason that competency is measured against this same level each year, and yet the FCA has recently confirmed it is aware that not all firms test their advisers’ knowledge yearly as part of their SPS, with many never retesting at all.

But change is on the horizon. It is only a matter of time before advisers will be compelled to demonstrate competency annually, in one shape or form.

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