An independent test to establish the knowledge gained by advisers carrying out qualifications gap-fill before 2013 has been ruled out by the FSA.
In today's Policy Statement on its RDR professionalism rules, the regulator says that would be inconsistent with its 'no regrets' approach, under which advisers who hold a relevant QCF Level 4 qualification will not be required to sit further exams.
Today the regulator confirms accredited bodies will instead be responsible for ensuring advisers have completed gap fill.
It will also be up to them to decide the basis on which they want to check advisers' gap-fill activity.
How the FSA determines whether individual retail investment advisers are keeping up to date with knowledge has been a sticking point among advisers.
The FSA today clarified its final position on qualifications gap-fill:
We are maintaining the principle behind the ‘no regrets' policy that we set out in FS08/631 in November 2008 - that an adviser with a higher level appropriate qualification does not need to sit further examinations, but can instead fill gaps between their qualification and the 2010 examination standards.
We have agreed that existing CPD can be used for qualifications gap-fill. Learning outcomes achieved through other qualifications that are not on our appropriate examination list may also be used where they meet the gaps.
Some gap-fill tools that are already available offer a generic gap analysis between the 2004 and the new 2010 examination standards, while others tend to identify the gaps between the provider's qualification and the new 2010 standards.
The second approach means that the gap analysis is tailored to the qualification held by the individual and is why it may not be made more widely available; the route to qualification taken may result in a wider gap than the generic analysis because of the combination of modules taken.
We have included a template in Appendix 7G of TC that clearly shows the gaps that we want advisers to check they have filled.
This enables the advisers who do not hold a qualification that has been analysed for gaps, or who cannot access those tools, to use the template to record their gap-fill activities and present it to their chosen accredited body in due course.
The new exam standards were published by the FSSC in March 2010, so the template in this paper reflects those final standards and is therefore slightly different from the version that we published in CP09/31. Advisers may use either template (or gap-fill tools based on them), as we are content that the difference between the two versions is not material, given that we want to be pragmatic.
The earlier template covers protection, which is not included in the new one, so if advisers choose to use the earlier template, they can ignore the protection section.
Transitional qualifications already cover a lot of the total required learning outcomes. Some gap-fill tools measure the gap as a proportion of the remaining
learning outcomes (as opposed to the gap to completing the full qualification).
We reiterate that gap-fill should be structured, rather than unstructured, CPD. However, if structured CPD is not available to fill the gap identified, then an adviser may complete the gap by reading suitable material. We expect that such cases would be for a minority of gaps, if any.
In common with other CPD activity, the adviser's gap-fill record should include:
• the target learning outcome and the associated indicative content; and
• a record of the learning activity completed including a description of how the activity
has given them the knowledge that they need to achieve the learning outcome.
Consistent with our intention to place greater emphasis on the role of accredited bodies, we expect them to satisfy themselves that where advisers hold an appropriate qualification that requires gap fill, 100% of their advisers have met that requirement.
It is for accredited bodies to determine the basis on which they want to check advisers have completed their gap fill.
Alternatives where the adviser is required to provide evidence of knowledge gained, such as passing some sort of independent test, are not consistent with the ‘no regrets' approach, under which the adviser does not need to pass further examinations.
Where an adviser moves from one accredited body to another in future we will not require the receiving accredited body to re-check an adviser's gap fill.
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