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.