It also signifies that a firm’s staff, where members of the CII, are governed by a Code of Ethics, and that disciplinary sanctions are applied to those who transgress.
A Chartered title is therefore an overall commitment to excellence and professionalism.
The CII has analysed how other professions (such as accountancy and the law) define and express professionalism. Where appropriate, we have incorporated these views into our own approach, enabling us to assemble a list of characteristics that articulate professionalism in insurance broking and financial planning.
It should be noted that, while the CII is a professional body that monitors and, where necessary, disciplines its members (the CII can and does publicise the withdrawal of Chartered titles from members), we do not police or regulate all the areas mentioned below. In some instances, these are the responsibility of the FSA or other bodies. But we believe that all professionals should comply with these requirements, irrespective of how they are governed.
A management with the experience and expertise to ensure the business model is sustainable and to implement the model effectively.
Encouragement of professional standards for employees through support for technical training and the development and encouragement of appropriate behaviour.
Q3. Why has the CII changed the criteria for Chartered firms from that which applied at launch in 2007?
A: The CII regularly reviews its services to ensure they continue to meet the needs of the market.
As part of this process we gathered market views (via the Insurance Broking Faculty, the Personal Finance Society and the CII Professional Standards Board) and added these to feedback received since the scheme was launched. After assimilating this information we have made two important changes:
- We have introduced additional compulsory eligibility criteria for Chartered status to further reinforce high standards of professionalism through increased levels of knowledge and enforcing ethical practice. This includes requirements that all firms must have both a formalised staff development programme along with core values and practices that align with the CII’s industry-standard Code of Ethics.
- The criterion that required 50% of the Board to be Chartered title-holders in their own right has been replaced with additional criteria covering a range of practices and behaviours associated with commitment to professionalism. Each element has a points value, with a minimum of 50 points required in total.
The full points total in respect of the discretionary criteria can still be attained if 50% of the Board team are individual Chartered title holders (comparable titles from other awarding bodies may be recognised – terms and conditions apply). In practice, however, we expect the majority of firms to comply via meeting a range of the discretionary criteria which, in the main, relate to the qualified status of key groups of employees.
Q4. The requirements relating to the Board or Partnership have been extended to include ‘highest management team’. Why is this?
A: Corporate Chartered status is designed to attract the best firms from across the broking and financial planning sectors. To do this, it needs to reflect corporate structures and practices.
Increasingly, organisations are being established whose principal business is not insurance broking or financial advice, but which have specialist divisions dedicated to this business. It would be both unfair and impractical to require the main board of such an organisation to meet the requirements of corporate Chartered status – this more properly lies with the relevant management team. For this reason the CII may, at its discretion, recognise the highest management team of a specialist division.
Q.5 Can a sole trader who holds a CII Chartered title apply for corporate Chartered status?
A: Sole traders are unincorporated and self employed and therefore have unlimited liability from personal assets for any business debts. If you are a sole trader and a Chartered title holder, you can use your individual title ‘Chartered Financial Planner’ or ‘Chartered Insurance Broker’ to describe yourself. However if you wish to obtain a corporate Chartered title which would enable you to describe your firm as ‘Chartered Financial Planners’ or ‘Chartered Insurance Brokers’ then you will have to apply using the normal application form and you will be required to pay the same fees as a small firm.
Q6. Can both limited liability companies and partnerships obtain Chartered status?
A: Yes
Q7. Can a partnership, where all partners hold the individual Chartered title, call themselves ‘Chartered Insurance Brokers’ or Chartered Financial Planners’?
A: Yes, where 100% of the partners hold the same Chartered title as the firm is to be described (e.g. all partners must hold the Chartered Financial Planner title for the firm to use the title Chartered Financial Planners), then the firm may use this description without submitting a full corporate Chartered application. We ask that firms wishing to use this description register with the CII by completion of a simple application form (ref: CCT010 – Application for use of Chartered title by 100% partnership).
This does not entitle the firm to use the CII corporate Chartered marque, or to be listed on the CII Chartered Firm Directory. If a firm wishes to use these, they should apply for corporate Chartered status using the normal application form, and would be required to pay the normal application fee.
Q8. Is this offer open to networks?
A: No. A network is a collection of individual firms and each individual firm must apply in its own right.
Q9. How do I decide which of my staff should be included within the requirement that 90% of customer-facing staff should be CII members?
A: Ideally the CII would require 100% of customer-facing staff to be members however the 90% rule is a practical guide on membership requirements. By requiring, as a minimum, only 90% of customer-facing staff to be members, firms are able to exclude staff whose customer-facing activities are peripheral to the firm’s business activities. It also provides a degree of protection in respect of natural fluctuations in staff numbers, which could otherwise lead to a contravention of the membership requirement.
For guidance, all staff acting in an advisory capacity need to be members. Beyond this, any member of staff that has customer contact should be included, such as para-planners, account-handlers and personal assistants who regularly liaise with clients. Typically, however, this would not include accountancy personnel, receptionists or the like, though it remains at the firm’s discretion as to whether to include these positions.
Q10. What is the definition of an executive director?
A: If directors run the company on a day-to-day basis and employees are accustomed to act in accordance with their instructions, they are deemed to be executive directors. In the case of a limited liability company, all the directors are executive unless they have been appointed in a non-executive capacity.
Non-executive directors have no operational role and do not make decisions on a day to day basis. Their role is to offer a different perspective to the Board and to make a creative contribution to the Board by providing objective criticism. Non-executive directors are appointed to that position (they will have a letter of appointment designating them as such).
Q11. Do the requirements relating to directors/highest board members/partners include retired or ‘silent’ partners?
A: All directors/highest board members/ partners need to meet all the requirements regardless of whether they are retired or 'silent' partners. In UK law, all directors are legally liable and collectively responsible for board decisions and for this reason we require then to adhere to the CII/PFS code of Ethics through virtue of their membership.
Q12. Are self-employed consultants included in the membership requirement?
A: All advisers registered to the firm (including self employed and contracted advisers) are required to be members (and, hence, signed up to the PFS/CII Code of Ethics) and beyond that, any member of staff that has customer contact should be included.
Q13. I have a number of part time staff, do they all have to become members?
A: Yes, if they are customer-facing.
Q14. Your guidelines state that other Chartered titles are comparable to the CII’s Chartered title when applying for Chartered firm status, so why haven’t I been given the equal number of credits towards an individual CII qualification (e.g. Advanced Diploma) for my non-CII chartered title?
A: The comparison that has been undertaken is in terms of overall professionalism and an obligation to follow a specified rather than the content of any learning undertaken. Where sufficient overlap in syllabus content between CII and non-CII exams exists, the CII will award credits. See www.cii.co.uk/individual-accreditation
Q15. If 90% of customer facing staff have to be members of the CII is this not simply a way for the CII to get more members and increase its revenue?
A: No. This is about ensuring a common standard across the market which can be relied upon by anyone who transacts with a firm holding the title. All CII/PFS members are required to comply with a Code of Ethics, reinforcing ethical practice, which is a key element of the Chartered concept.
Q16. Not every employee in a firm has to be Chartered in their own right. Is this not misleading to the consumer?
A: All professional firms operate with a variety of disciplines and with staff at various levels of experience. A Chartered accountancy firm, for example, may have accounting technicians, part-qualified accountants and fully-qualified chartered accountants. Each individual is assigned work within their level of competence and is supervised by a fully qualified accountant.
The same applies for Chartered insurance broking and Chartered financial planning firms. The CII Code of Ethics and Chartered rules require that individuals only operate within their levels of expertise and that the firm is overseen by a Board/Highest Management Team/Partnership which in most instances has 50% of its members qualified to Chartered level). Further, one of the directors or equivalent is a designated ‘Responsible Member’, part of whose responsibilities is to ensure the CII Code of Ethics and Chartered rules are adhered to by all staff members.
Our rules are consistent with those of other professional bodies.
Q17. Is there a minimum number of directors/management team member/partners that a firm must have?
A: No, but at least one director, highest management team member or partner must hold the CII Chartered title for which corporate status is requested. That director or partner must be the Responsible Member.
Q18. Can executive directors/highest management team members/partners use other professional qualifications to qualify. If so, what qualifications are acceptable?
A: The CII will recognise Chartered titles from other awarding bodies as being comparable to the CII’s individual Chartered title, providing: the title held is directly relevant to the individual’s principal area of work; and the awarding Chartered body concerned has a Code of Ethics comparable to that of the CII.
Directly relevant to the individual’s principal area of work means, for example, that a firm’s accountant who is a Chartered Accountant may be counted towards the discretionary individual Chartered requirement (provided that the accountant is only acting in this capacity [accountant] for the company and does not advise clients, either as a broker in a firm of Chartered Insurance Brokers or as a Financial Planner in a firm of Chartered Financial Planners).
A listing of the Chartered titles which the CII will automatically recognise as equivalent can be found at Comparable Third Party Titles. Other organisations will be considered on application.
Q19. Can a single firm hold more than one corporate Chartered title?
A: In accordance with the Bye-laws of the CII, it is only permissible for a company or partnership to describe itself using the plural of a single chartered title.
Q20. Is there a Charter marque for firms to use on their marketing material?
A: Yes. There is both a marque and a form of words that can be used on company stationery, company signage, web, etc. Full brand guidelines details can be found online at cii.co.uk/chartered
In addition, firms can use their Chartered status in a variety of ways to reinforce their credentials and demonstrate their commitment to providing customers with a professional service. These range from including details in client proposals through to issuing a press release to issuing a communication to existing customers. A guide to maximising the benefits of being Chartered is issued to each firm when it attains Chartered status.
Q21. What responsibilities and obligations attach to the nominated ‘Responsible Member’?
A. The responsible member has four principal obligations:
1. The Responsible Member is the focal point for all matters concerning the use of the corporate descriptor Chartered Insurance Brokers/Chartered Financial Planners. Guidelines, rules and regulations will be issued from time to time, and it is the Responsible Member’s responsibility to ensure their firm’s Board/Highest Management Team/Partnership is fully aware of those requirements. The Responsible Member will personally be expected to take all reasonable steps to ensure their Board/Highest Management Team/Partnership meets its obligations, and they must notify the CII at the earliest opportunity where there are circumstances preventing compliance.
2. If a firm falls below the requirements for Chartered Insurance Brokers/Chartered Financial Planners status, the Responsible Member must notify the CII immediately. The firm’s authorisation to continue to use a Chartered title may be at risk, irrespective of the reasons for non-compliance. In the event of non-compliance, the CII will work with the Responsible Member to overcome short-term difficulties, agreeing necessary remedial action together with a proposed timescale. It is not possible to define any such “period of grace” but the CII will take into account the circumstances of each case and will be fair both to the Chartered title-holding company and other CII stakeholders. The CII will not, however, sanction long-term default.
3. Paragraph 4.7 of the Code of Ethics requires that members: “act only within your ability and authorisation and seeking help where necessary”. Responsible Members are expected to take all reasonable steps to ensure their Board/Highest Management Team/Partnership is aware of its obligations in this regard and to notify the CII where a reasonable view is that the breaches are anything other than “one-off” exceptions in respect of which corrective action has been taken to prevent reoccurrence.
4. Each year the Responsible Member will receive a renewal reminder. It is their responsibility to submit the firm’s application for renewal and to ensure the information provided is complete and accurate, to the best of their knowledge. This includes:
- that the firm continues to satisfy both the compulsory and discretionary eligibility criteria on which their Chartered application is based, notifying the CII where this is not the case;
- having made due enquiry, certifying that staff members notified to the CII under this scheme have complied with any CPD obligations that apply. The personal CPD of the Responsible Member must also be up to date;
- they must also sign a declaration that they have no reason to believe any individual in their firm has committed a breach of the CII’s Code of Ethics. Where they become aware of any such breach mid-term, they must notify the CII immediately and not wait until renewal.
5. If the firm wish to change their Responsible Member they are required to notify the CII without delay. The newly-appointed Responsible Member should submit a Change of Responsible Member form, which includes signing a declaration similar to that included in the initial application form. This form can be requested from CII Customer Service or found at www.cii.co.uk/charteredcomms
Q22. Are firms to be audited/inspected by the CII?
A: Yes. As part of the its monitoring and disciplinary procedures, the CII will be undertaking audit visits.
By applying for corporate Chartered status, a firm (and its staff) commits to achieving compliance with the stated requirements now and at each subsequent renewal. To ensure compliance with the scheme criteria, the CII retains the right to validate any declarations made. This can include, but is not limited to, requests for additional supporting documentary evidence and personal visits to a firm’s premises. Personal visits/telephone interviews may be undertaken on the firm’s initial application, at any subsequent renewal or at any time between renewals, at the discretion of the CII.
If a firm is found not to comply with the specified requirements of corporate Chartered status, it may be refused the award or an existing award may be withdrawn. The CII liaises with other organisations such as the regulator, both within the UK and overseas, to monitor the activity of Chartered firms to ensure the scheme rules are not being contravened.
Firms are required to submit an annual renewal confirming their compliance with the eligibility criteria. This will include submission of the same information required on the initial application to ensure that all criteria are still being met. The CII will monitor any complaints received directly from the public or any actions which are likely to constitute grounds for non-compliance, such as action taken by the FSA.
Q23. How does the CII handle consumer complaints against a Chartered firm? What redress does the CII provide to the consumer if a complaint against a Chartered firm or member is upheld?
A: As the CII is not the regulator of firms or individuals, consumer complaints regarding, for example, policy coverage or the performance of an investment product, will be dealt with by the existing complaints mechanisms run by the Financial Services Authority (FSA) or Financial Ombudsman Service (FOS).
In every case of complaint, however, the complainant must contact the firm concerned in the first instance. If a complaint concerns an individual member’s behaviour, any breach of the CII’s Code of Ethics will be dealt with by reference to the CII’s Disciplinary Procedures (see Guide to Member Complaints on the “Contact Us” section of the website cii.co.uk/cii/about/contactus).
Q24. What happens if one of my staff is subject to disciplinary proceedings of the CII or other professional, statutory or regulatory body?
A: In the case of CII disciplinary action, they will be notified by us. It is important that they take this seriously and that they attend any disciplinary hearing. The disciplinary panel has a variety of remedies at its disposal.
You should be aware that the disciplinary panel can withdraw individual Chartered status and recommend to the CII the withdrawal of corporate Chartered status, where the circumstances warrant this sanction.
Where another professional, statutory or regulatory body applies sanctions to an individual member of staff, full details (including the nature of the offence committed and details of the sanction applied) must be notified to the CII immediately. The CII will then consider whether the offence prejudices your firm’s licence to use the corporate Chartered title.
Q25. What do I do if my firm ceases to meet the stated eligibility criteria?
A: You must notify us immediately should you cease to meet the eligibility criteria on which you applied. In turn, we will agree a realistic timescale for you to return to compliance with the rules. If you do not achieve compliance within that timescale, your licence to use corporate Chartered status may be withdrawn and corresponding use of the title must cease immediately.
Q26. What are the costs?
A: There is tiered fee structure based on headcount. The fees, which have been unchanged since 2007, have been kept at a level which reflects the costs to the CII in administering, monitoring and communicating the scheme. They also recognise the commitment made by firms in supporting CII/PFS membership/qualifications to-date. The pricing model was developed in consultation with the industry through the CII’s Professional Standards Board, faculties and societies.
Q27. Can I pay by credit card?
A: Yes, but not over the telephone. You can complete the details on the application form.
Q28. What is the rationale behind the current pricing levels?
A: The pricing model was developed in consultation with the industry through the CII’s Professional Standards Board, faculties and societies. The fees have been set to cover the administration, monitoring and communication costs associated with the scheme. The work includes verifying applicant’s details, confirming eligibility, producing and issuing certificates and enforcing the scheme rules. There is also a wealth of supporting literature, a dedicated website and a “live” online directory.
The CII is a not-for-profit organisation and, in the event that any surplus is generated, this will be reinvested in the work and membership services of the CII and PFS.
We are confident that corporate Chartered status delivers value to those firms which attain it. It distinguishes them from the bulk of the market and highlights their credentials as trusted advisers. In turn, this enhances their professional standing and their potential for commercial success.
Q29. What plans do the CII have to raise the profile of Chartered status?
A: The CII is committed to raising the standing of the profession of individual and corporate Chartered status in the eyes of the public. We are investing considerable resource to achieve this aim and will develop our approach in conjunction with the Faculty of Insurance Broking or Personal Finance Society, as appropriate.
Introducing changes of this nature, in particular influencing consumer understanding, takes time. That said, we look forward to the challenges ahead and remain confident that our goals will be achieved.
Q30. Can a Chartered firm change their name to call themselves (Company name) Chartered Financial Planners/Insurance Brokers?
A. Companies may not use the word “chartered” in their registered or other company names and any firm purporting to do so will not be accepted for a Chartered title.
The only permitted stylistic representation of Chartered titles is as follows:
- XYZ Ltd, Chartered Insurance Brokers; or
- X,Y & Co, Chartered Insurance Brokers; or
- X and Y, Chartered Insurance Brokers; or
- X,Y & Z, Chartered Insurance Brokers.
A company may apply to use a trading style incorporating words including “chartered” - applications should be addressed to the Secretariat department.
Under no circumstances are Chartered titles to be shortened e.g. Chartered Insurance Brokers must always be written in full as Chartered Insurance Brokers never as CIB.
Q31. Can firms request additional certificates to display on their premises?
A: On initial application, firms can request as many certificates as they require in order to display one certificate in each of their offices. If, subsequently, the firm requires additional/replacement certificates, a fee of £10 per additional certificate will be charged.
Q32. What is the process for firms that cease trading/wish to cancel their corporate Chartered status?
A: Firms who cease trading or wish to cancel their Chartered status should inform the CII immediately. They should also return all Chartered certificates to the CII as soon as possible.
