Our RDR frequently asked questions covering gap fill, SPS, and CPD are answered on this page.
These are bookmarked into the following five categories:
Qualification gap fill
Q1: Why will my gap fill need to be verified?
A: As an accredited body, the CII is responsible for issuing Statements of Professional Standing (SPS) for retail investment advisers. Authorised advisers must have an SPS by 1 January 2013. Advisers submitting an SPS application need to evidence that they hold the required qualifications for the activities they undertake, including completion of gap fill if relevant. The FCA also require gap fill to be signed off by an accredited body. It will therefore be necessary for gap fill to be successfully verified prior to an SPS application being made.
Q2: What will the verification process involve and how long will it take?
A: Verification of gap fill by an accredited body involves reviewing the evidence provided to see that it adequately describes the activity undertaken, that the activity clearly relates to the relevant learning point(s) and that the member has confirmed that the activity has met the required learning point(s).
The CII will aim to process gap fill submissions within 60 days. The overall time taken for the CII to verify gap fill records will vary. A key factor affecting the time taken will be the amount of non-CII/PFS gap fill solutions logged against a record. As these activities will initially be unfamiliar to us, they will take longer to verify than solutions offered by the CII/PFS. Records will also be verified in the order we receive them, so those further down the queue will take longer.
Demand for gap fill record verification, and the volume of submissions at any given time, will also impact the time taken.
Q3: How can I submit my gap fill record to the CII for verification?
A: 'Verification' functionality within the gap fill tool allows adviser members to submit their completed gap fill record to the CII for checking. As part of this process, you will be required to make a declaration about your submission. The wording of that declaration is as follows:
I confirm that the information contained in this submission is, to the best of my knowledge, a true and accurate record of the activities I have undertaken to complete qualification gap fill and, having undertaken these activities, I have now satisfied all my knowledge gaps.
I confirm that I hold, or am in the process of completing, a level 4 (or higher) 'transitional qualification' from the FSA's list of appropriate qualifications.
I also acknowledge that, as a CII/PFS member, any false statements made about activities undertaken to complete qualification gap fill could result in disciplinary action by the CII.
I further acknowledge as a CII/PFS member, that any judgement of the CII Disciplinary Panel, whether related to verification of qualification gap fill completion or not, may be notified to the FSA.
I also expressly agree that any and all data relevant to the verification of qualification gap fill completion, or which may reasonably have a bearing on my regulatory status, may be exchanged with my employer, the FCA, any FCA-authorised Accredited Body or any other body or person deemed by the CII or FCA to have a legitimate interest in the verification of qualification gap fill completion.
Version 2 (dated 1 December 2011)
Upon notification that verification has been successful, members will be able to apply separately for a CII SPS.
Important note: Providing the appropriate information when self-recording your own gap fill activity is essential and will ensure that when it comes to verification of your gap fill record, we have all the information we need. If you have documentary evidence supporting your entry such as an event attendance certificate, you can upload this.
Visit: www.cii.co.uk/gap-fill-guidance to access our best practice guidelines.
Q4: How will I know if my gap fill record has been successfully verified?
A: Members will be notified by email. Where gap fill cannot be successfully verified, guidance will be given on which learning points failed verification and why. Members can then address any issues, and, when ready, re-submit their record for verification. Where verification is successful, a copy of the email should be retained in case you are required to produce it as evidence of gap fill completion by your employer, another accredited body or the regulator.
Q5: I am not currently a retail investment adviser but I intend to become one in the future. I hold a level 4 transitional qualification from the appropriate qualifications list - will I be able to complete my gap fill and submit it for verification before becoming an adviser?
A: Yes. We will be able verify your gap fill completion even though the FCA do not require you to do this in your current role.Note:In order to provide retail investment advice, you must be authorised by the FCA. Meeting the RDR exam standards alone is not sufficient.
Q6: Is it absolutely necessary for me to use the reflective questions available within 'in-tool' PDF learning activities prior to submitting my gap fill record to the CII for verification?
A: Adviser members completing gap fill will need to declare that they have satisfied their knowledge gaps when submitting their record to us for verification.
This declaration is a legal undertaking which places the onus on individual advisers to satisfy themselves that their gap fill activity has been sufficient.
To help, we've added a number of reflective questions to all gap fill solutions provided as PDF documents in the tool (the questions relate directly to the learning content and no answers are given).
We would urge all adviser members to use these questions to reflect on their learning and assess whether they have met their learning points.
The updated learning material incorporates legislative changes for the 2011/2012 tax year (you won't need to re-do activities simply because of these changes).
Q7: I have realised that I have forgotten to include some important attachments in my submission. How can I amend my submission now that it has been sent for verification?
A: You can cancel your submission up until midnight on the day of submission. You will see a link on your gap fill record home page that will allow you to do this. Once you have cancelled your submission you will be able to make any necessary amendments and then resubmit it. If you do not cancel your submission before midnight, you will need to contact CII Customer Service to cancel this for you.
Q8: What will the verification process involve and how long will it take?
A: Verification of gap fill by an accredited body involves reviewing the evidence provided to ensure it:
- adequately describes the activity undertaken;
- that the activity clearly relates to the relevant learning point(s); and
- that the member has confirmed that the activity has met the required learning point(s).
If the whole of your gap fill submission meets these criteria then it will be successful and you will be notified of the result.
Any one gap that does not meet these criteria will result in the whole submission being marked as unsuccessful. If this happens, you will receive an e-mail explaining why your record was unsuccessful and what you need to do to rectify the problem. Your gap fill record will be reopened in the gap fill tool to enable you to make the necessary changes and resubmit your record.
The main problems that we anticipate could result in your submission being unsuccessful are:
- Insufficient evidence.The evidence provided for a learning point does not give enough detail about the CPD activity undertaken.
- Incorrect/missing attachment.The evidence against a learning point refers to an attachment that is either missing or does not appear to correspond with the activity description and/or learning point.
- Evidence does not relate to gap.The evidence provided does not appear to correspond with the learning point it is recorded against.
To avoid this happening, please ensure that you have checked your record thoroughly before submission and are satisfied that you have provided all the information we need to verify it. Guidance on how to fill in your gap fill record adequately is provided within the gap fill tool.
You should allow up to 60 days for your gap fill to be verified. However, it is expected that the time taken for the CII to verify gap fill records will vary.
A key factor affecting the time taken will be the amount of non-CII/PFS gap fill solutions logged against a record. As these activities will initially be unfamiliar to us, they will take longer to verify than solutions offered by the CII/PFS.
Demand for gap fill record verification, and the volume of submissions at any given time, will also affect the time taken.
Q9: I'm not a CII/PFS member, will you verify my gap fill completion?
A: No, you must be a CII/PFS member to use this service.
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SPS - general
Q1: What is a Statement of Professional Standing (SPS) and how do I obtain one?
A: It will be a requirement from 1 January 2013 for all retail investment advisers to hold an SPS, issued by an Accredited Body. This confirms that an adviser adheres to ethical standards, holds appropriate qualifications for their role (including completion of gap fill) and has undertaken appropriate CPD during the year. The SPS is renewable on an annual basis.
The CII, as an Accredited Body, is authorised to issue statements of professional standing. This service is available to members of the CII/PFS only. You can apply online for your SPS at: www.cii.co.uk/sps
Q2: What is the definition of a "retail investment adviser"?
A: The FCA Handbook glossary states that a retail investment adviser is "an employee who carries on activities 2, 3, 4, 6, 12 and 13 in TC Appendix 1.1.1 R". For more information, please visit: (http://fsahandbook.info/FSA/html/handbook/TC/App/1/1)
Q3: How do I apply for an SPS?
A: You need to go to www.cii.co.uk/sps. You will go through an online application process to submit your request for an SPS. The length of time it will take you to complete the application will vary depending on your individual circumstances. Please remember, that only CII/PFS members are able to apply for a Statement of Professional Standing issued by the CII.
Q4: When is the latest I can apply for my first CII statement of professional standing?
A: Although advisers with competent adviser status on or before 31 December 2012 need to hold a statement of professional standing (SPS) from 1 January 2013, there are a number of important points that need to be considered when deciding when to apply:
1. Gap fill, if applicable, needs to be completed and verified by the CII before an SPS application is made. Existing advisers (defined by the FCA as advisers deemed competent on or before 30 June 2009) are required to fulfil their RDR qualification requirements, including completion and verification of gap fill, by 31 December 2012.
2. Advisers should allow up to 60 days for their gap fill record to be verified and their SPS application approved. Therefore, as a minimum, you should submit your completed gap fill record to the CII for verification by 1 October 2012.
3. Although the FCA rules provide a 60 day grace period from 1 January 2013 within which an adviser must obtain their SPS, we strongly recommend advisers complete gap fill and obtain a CII SPS well in advance of the start-of-2013 deadline to ensure timely compliance with FSA requirements.
Q5: What information will I need to provide to get an SPS?
A: The first time you apply for an SPS we will ask you for the following information:
- Your FCA Individual Reference Number
- The relevant T&C Appendix 1.1.1R activities (http://fsahandbook.info/FSA/html/handbook/TC/App/1/1) you are authorised to undertake as a retail investment adviser
- Confirmation of the appropriate qualifications you hold (including completion of qualification gap fill if relevant) for each relevant T&C Appendix 1.1.1R activity undertaken. (If the qualifications held were awarded by the CII we will be able to confirm these from our records.)
You will also be required to make a declaration that, in the last 12 months, you have complied with the requirements of APER and have undertaken appropriate CPD. You will not need to provide this information again at renewal (unless the activities you undertake have changed). You will however be required to make the same declaration each and every time you apply for an SPS.
Q6: I am a trainee retail investment adviser, not yet assessed as competent. Do I need an SPS?
A: No, the FCA has stated that pre-competent advisers do not need to have an SPS.
Q7: How long will it take before I receive my SPS?
A: As an accredited body, the CII will need to carry out various checks to ensure you can receive an SPS. You should allow up to 60 days for the CII to process an SPS application, including verification of gap fill, and so members have until early September 2012 to submit their SPS application and still be RDR ready for 1 January 2013.
Q8: How long will the SPS be valid for?
A: The CII will be issuing initial Statements of Professional Standing with expiry dates which match those of your annual membership expiry. For any SPS issued in 2011 this date will be the 2012 membership renewal date even if the member has a renewal date in 2011. This is to prevent short dated SPS expiry dates. Once the first SPS has been issued, all future SPSs will last for a full 12 months with an expiry aligned to the membership renewal.
Q9: How will the SPS be issued to me?
A: Successful applicants will receive an electronic SPS which can be downloaded and printed off on demand.
Q10: Can I apply for an SPS without being a member of the CII/PFS?
A: No. The CII is only issuing SPSs to adviser members of the CII/PFS. This service is being provided as a complimentary part of the membership package.
Q11: How much does it cost to apply for a CII SPS?
A: The CII is only providing Statements of Professional Standing to members of the CII/PFS. We are not making any additional charge to issue an SPS as the service is being provided a part of the overall membership package for retail investment advisers.
Q12: How can I adhere to the CPD requirements for getting an SPS as the new rules have yet to be introduced?
A: As the new regulatory CPD requirements do not come in to force until 1 January 2013 the CII will issue an SPS on the basis of existing member CPD requirements. The CII is planning to introduce a new scheme based on the new regulatory requirements in mid 2012. This will allow time for adviser members to transition to the new regulatory requirements in advance of the deadline. Further details of the launch of the CII CPD scheme will be communicated in the coming months.
Q13: Can I apply to the CII for an SPS if I hold a non CII qualification that is recognised by the FCA?
A: Yes, but please note the CII will not issue membership designations for non CII qualifications.
Q14: I hold a non CII qualification recognised by the FCA. If I apply for an SPS from the CII will I automatically get recognition of prior learning?
A: If you require recognition of prior learning (RPL) for non-CII qualifications, please use the separate RPL application process. RPL will not be granted on the basis of an SPS application.
Q15. Do I need to have a separate SPS for each relevant TC Appendix 1.1 activity I undertake as a retail investment adviser?
A: No. You only need one SPS to cover you for all the relevant activities you undertake. You are asked to confirm these activities as part of the application process and you should select all that apply to you.
Q16. I already hold an SPS obtained from another accredited body, can I apply for a CII SPS as well?
No. You should only hold one current SPS from a single accredited body.
Q17: I completed my qualification gap fill and had it verified by another accredited body but I want to apply for my first SPS from CII. Will CII accept this when I apply for an SPS?
A: Yes, but you must be able to provide evidence to support this. Suitable evidence includes written confirmation from the Accredited Body of gap fill verification or a certificate issued by the Accredited Body. You will need to submit this evidence in an electronic format via our online service at www.cii.co.uk/sps
Q18: I am a CII/PFS member and hold a 'transitional qualification' that wasn't awarded by the CII. Can I apply for a free CII SPS?
A: Yes. However, before submitting your application, you will need to bridge any potential knowledge gap between your qualification and the full RDR exam standards through qualification gap fill. There are two options:
- complete gap fill with, and get this signed off, by another Accredited Body then submit a CII SPS application via our online service at www.cii.co.uk/sps - if you were awarded the qualification by an organisation that's been given Accredited Body status, we recommend you choose this option
- complete gap fill with, and get this signed off, by the CII then submit a CII SPS application via our online service at www.cii.co.uk/sps - if you don't hold a relevant CII unit by examination or accreditation, you will not automatically have access to the online gap fill tool, and will need to contact CII Customer Service in order to gain access.
Q19: I currently hold an SPS issued by the CII but I am about to go on maternity leave and will not be actively working as a retail investment adviser for the next 6 months. Do I need to cancel my SPS?
A: It is not necessary to cancel your SPS in these circumstances (or for other reasons of leave from the workplace, eg long-term sickness absence). It will expire once the renewal date becomes due. You can renew your SPS as and when you return to the workplace.
Q20: I currently hold an SPS but am leaving the industry. Do I need to cancel my SPS?
A: You can cancel your SPS by contacting our Customer Service team at email@example.com. If you are no longer a retail investment adviser you should destroy any copies you hold of your SPS.
Q21: What happens if the CII refuses to issue me with an SPS?
A: In the first instance you have the option to apply to another accredited body for your SPS. If you cannot obtain an SPS from any accredited body you should notify your employer (or the FCA if self-employed). Be aware that we are also required to notify the FCA and your employer if we refuse to issue you with an SPS.
Q22: What happens if the CII withdraws my SPS?
A: If we withdraw your SPS we are required to notify you, your employer and the FCA. The FCA will, in conjunction with your employer, decide what action needs to be taken.
You also have the option to apply for a new SPS from another accredited body.
Q23: Does the SPS mean I now have two licenses to trade and two regulators?
A: No. The FCA retains all control of regulated individuals and firms and is the only body that can grant or revoke your authorisation to trade. Your FCA-approved person status of CF30 continues to be the only legal licence to trade as an adviser. The SPS issued to you by the CII provides evidence that you are adhering to the professional standards required of you.
Q24: Do I have to display the SPS in my office or show it to my clients?
A: There is no requirement to display your SPS, but you are encouraged to show this to your clients.
Q25: I am a financial adviser vetted by the Isle of Man Financial Services Authority (“the Authority”), do I need to apply for an SPS?
A: Yes. An Isle of Man Adviser providing investment advice to retail clients must hold an Isle of Man SPS.
The SPS must be issued in the previous 12 months by a professional body accredited by the Authority. For more details please visit the Authority’s website at: www.iomfsa.im
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SPS - renewals
Q1: How do I renew my SPS?
A: Like initial SPS applications, SPS renewal applications are made online. Visit www.cii.co.uk/spsrenew and 'proceed to the SPS application centre' using the link at the bottom of the page.
Q2: How far in advance of the expiry date will I be able to renew my SPS?
A: The window for renewing your SPS will open one month before your existing SPS is due to expire, and you can renew any time during that period. Note: Your SPS expiry date is the same as your CII/PFS membership expiry date.
Q3: Can I renew my SPS before my membership?
A: Yes. However, your membership must be renewed and up-to-date before your new SPS is emailed to you.
Q4: How long will it take for my SPS to be renewed?
A: Like initial SPS applications, you should allow up to 7 days for your new SPS to reach you. Note: The renewal process may take longer than 7 days if you haven't yet renewed your membership at the time of applying.
Q5: What if my activities have changed since the last time I made an SPS application?
A: During the online renewal application you will have the option to 'renew your SPS with new activities'.
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SPS - employers
Q1: Can I apply for SPSs on behalf of my employees?
A: It is an FCA requirement that an individual must personally declare compliance with the CPD and APER requirements.
Q2: I would like all of my employees to have an SPS, including those who are not retail investment advisers, to show our commitment to professional standards. Can non-retail investment advisers apply for an SPS from CII?
A: The FCA's rules apply to retail investment advisers only therefore the CII will not be issuing SPSs to any other type of authorised person.>
Q3: Will CII be checking that the individual has complied with the Statements of Principle for Approved Persons (APER) and CPD requirements?
A: When the adviser declares that they have complied with these two requirements, this is a legal undertaking that they have done exactly that.
Compliance with the Statements of Principle for Approved Persons (APER) is an existing regulatory requirement which has its own set of rules and procedures for monitoring and reporting. As a regulated firm, you have a duty to monitor this and report any issues to the FCA. Accredited bodies have no powers to monitor compliance with APER or investigate issues - that remains solely with the FCA.
If you become aware of a competence or ethics problem with one of your advisers you should continue to follow your existing procedures for dealing with this. If, however, you feel the matter has a bearing on the SPS issued to the adviser, please also notify the CII and we will review the case and take action as appropriate.
As an accredited body we are required to sample, on an annual basis, the CPD records of 10% of advisers to whom we have issued an SPS. If during that sampling process we discover that an adviser has not complied with CPD requirements we will take action as necessary.
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Q1: What will the new CPD requirements be for retail investment advisers?
A: As part of its objective to introduce a step change in the professional standards required of advisers, the FCA has declared that retail investment advisers (RIAs) will, from 1 January 2013, need to complete a minimum of 35 hours' compulsory CPD each year (of which at least 21 hours must be structured CPD). The current CII CPD scheme requires completion of 100 credits each year. This will be changed to meet the new regulatory hours based requirement from mid 2012.
Q2: What is the difference between structured and unstructured CPD?
A: Structured CPD is any activity undertaken designed to meet a specific learning outcome.
Unstructured CPD is any activity undertaken which is not designed to meet a learning outcome.
For example, an opinion about asset allocation expressed in one of the weekly trade magazines would be unstructured but an educational paper designed to set out a balanced view that will add to the adviser's technical knowledge would be structured.
Structured learning activities include: participating in seminars (web based or in person); lectures; conferences; workshops; courses; and completing appropriate e-learning. For a minority of activity, it might also include structured, educational reading, where quality reading material has been produced to meet the required learning outcome.
The activity should require a contribution of thirty minutes or more of the adviser's time. It does not include carrying out research on products and services for your client.
Q3: What is the difference between CPD for qualification gap-fill and ongoing CPD?
A: Qualification gap-fill is needed for advisers holding certain qualifications if they wish to meet the RDR qualification requirements by 31 December 2012. This gap fill activity must consist of structured CPD and must meet specified learning outcomes and is a one-off exercise.
Ongoing CPD consists of a combination of structured and unstructured activity and is designed to maintain your ongoing knowledge post-2012.
Q4: What should ongoing CPD cover?
A: Ongoing CPD will be different for each adviser member. You should review your competence on an ongoing basis and ensure you remain competent for your role.
Firms should ensure that their employees are maintaining their competence. Areas to take into account include:
- technical knowledge and its application;
- skills and expertise; and
- changes in legislation and regulation
Ongoing CPD should:
- address any learning gaps in your technical knowledge;
- maintain your knowledge so that you continue to meet requirements;
- be measurable (e.g. a seminar with the number of hours); and
- be capable of being verified by the CII as the accredited body (e.g. a CPD certificate, test result).
Q5: What evidence do I need to record?
A: You need to ensure you have good quality CPD records. The three areas your documentation should cover are:
- your needs - knowledge gaps and the target learning outcome;
- how you meet your needs - a description of the activity you are going to carry out / that has been carried out, including number of hours;
- and confirm you met your needs (once carried out) - how the activity has met the target learning outcome, and if tested, the test result.
Q6: Are there any additional CPD requirements?
A: In addition to the 35 hour requirement noted above, the FCA's other CPD requirements include:
- Structured CPD activities should be a minimum of 30 minutes in length.
- All CPD must be measurable and should consider learning outcomes.
- CPD undertaken must be relevant to retail investment advice activities. CPD undertaken for other purposes that are not relevant to retail investment advice activities will not count towards the 35-hour requirement.
The CPD requirement is the same for all RIAs regardless of whether they work full time or part time but it can be suspended in certain circumstances (eg long-term sickness absence).
Q7: What sort of audit will the CII carry out on my CPD?
A: Accredited bodies must audit a 10% sample of CPD records of RIAs to whom they have issued an SPS. As part of this check, the accredited body must check for evidence of the planning and review process.
Q8: When is the CII planning to introduce a new CPD scheme?
A: It is our aim to launch a scheme which meets the new regulatory requirements in mid 2012. This will allow adviser members about six months to move their existing CPD plans over to the new scheme.
Q9: How will I be able to record my CPD with the CII?
A: We will be launching a new online recording tool in mid 2012 which will enable all adviser members to record and maintain their ongoing CPD. Our aim will be to make the planning and recording process as simple as possible through this online tool.
Further details about the new CPD scheme will be communicated in the coming months.
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