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 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

ExamplesJohn 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

Examples of Good and Bad Evidence

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 2011. 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 - 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

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 email address rdr@cisi.org

Any Questions?