The FSA could wrench the mandate to update qualifications standards from the Financial Services Skills Council (FSSC), and force a review of the criteria every three years.
Currently control for maintaining and adjusting assessment standards rests with the FSSC.
But today the FSA has pointed to the need for a more rigorous review regime than is in place, and says it is uncertain whether the present arrangement should be allowed to continue.
It proposes reviewing exam standards every three years, which could mean advisers taking qualifications now as required by the 2012 deadline may no longer meet FSA criteria by 2015.
In CP10/12 Competence and ethics, the FSA states: "To ensure that examination standards continue to accurately reflect industry roles we propose to update the standards every three years rather than wait for FSA reforms such as the RDR.
"Currently, the FSSC updates the standards on our behalf and neither FSA nor FSSC have reached a view on whether this arrangement should continue."
The FSA is also proposing to look at the content of qualifications for non-RDR activities, including mortgage advice, insurance, and back-office activities, and whether these would benefit from reform similar to the widespread changes in investment advice as a result of the RDR.
"We are primarily concerned with ensuring that any qualification is fit for purpose and areas examined cover the actual activities and skills necessary to perform the associated role," the paper states.
Areas where the FSSC Appropriate Examination Standards (AES) have not recently been reviewed are likely targets for reform.
This could include long-term care insurance, last reviewed in 2004, mortgage advice last revised in 2004, similarly lifetime mortgage activities, and equity release, last looked at by the FSSC in 2007.
Several overseeing activities last reviewed in 2005 could also face scrutiny, including overseeing collective investment scheme administration, safeguarding client money, overseeing safeguarding and administering of investments or holding client money, overseeing investment management administration, overseeing life policy administration, and overseeing stakeholder pension administration.
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