FCA provides guidance on maintaining CPD

Many financial firms and organisations are continuing to operate despite the complications caused to business operations by the coronavirus. As a result, remote working has increased for those able to adapt.

In order to maintain ‘business as usual’, the Financial Conduct Authority (FCA) have clarified that they still expect firms to continue to demonstrate that relevant individuals remain competent to carry out their work[1]. While continuing professional development (CPD) is an essential part of this, the FCA also recognises the significant impact of the coronavirus and are allowing firms to defer individuals’ CPD to the following year. This applies to CPD years ending before 1 April 2021.

Professional bodies, such as the Chartered Insurance Institute (CII), are increasing their digital content to replace physical events so that people who are working from home, or have been furloughed, can continue to maintain their CPD. The CII requires individuals to complete a minimum of 35 hours' compulsory CPD each year of which at least 21 hours must be structured CPD.

The exceptional circumstances that may prevent those from completing their CPD for the year are outlined by the FCA as follows:

When individuals during the current pandemic:

• are needed to carry out extra duties to manage risks, and/or to provide support, to consumers and businesses during the current situation
• have caring responsibilities, such as having to care for a partner, child, parent, grandparent or sibling
• have difficulties accessing CPD material, for example, due to technical difficulties or unavailable material, and
• Where it is not realistic to expect the individual also to fulfil the CPD requirements.

We remind firms that we have rules in place for long-term illness implications, as described in TC 2.1.17.

Firms will need to take into account:

• the individual’s role and responsibilities
• the individual’s knowledge and skill development, (including any relevant COVID-19- related training) during the current CPD year and their continued competence
• the number of CPD hours they intend to carry over
• the individual’s circumstances during the current situation
• the reasons why the individual is unable to complete the relevant CPD

Firms should record their decision and the reasons for it, including the number of CPD hours the individual is carrying over to the next CPD year, but do not need to report this to the FCA.

Firms carrying on insurance distribution activities, who must ensure that each relevant employee completes a minimum of 15 hours of professional training or development in each 12-month period, may also experience difficulties ensuring individuals complete their CPD.

The CII welcomes the FCA’s statement to provide more flexibility around CPD. CPD is an essential part of remaining up to date so that professionals can serve their clients with expert advice, and act in their best interests. Most advisers will still be able to undertake the full CPD requirement, and we agree with the FCA’s expectation that ‘most individuals will be able to continue completing CPD whilst on furlough or working from home’. 

However, we understand that individual circumstances will vary, and some advisers are facing a huge range of urgent demands on their time, and are likely to do so for several more months. We have been giving these individuals help and support within the existing rules, and we had also asked the FCA to give them additional support with greater flexibility around the CPD rules. The FCA’s proposals deliver this flexibility. They are well thought through, and we anticipate being able to implement them with minimal bureaucracy for advisers. 

We would encourage any adviser that is struggling to meet the CPD requirements to contact us in the first instance – we often find that advisers are undertaking activities that can count towards CPD with relatively minor changes to the way the activity is planned and recorded

To provide further clarity, the CII have created a set of FAQs about how to complete and record CPD whilst working remotely. We are continuing to support members during this time by providing online CPD resources including online conferences, articles, webinars, podcasts and e-learning. Links to many of these are in our Society newsletters (currently sent to members weekly), on our websites and our social media channels, including LinkedIn and Twitter.

If members who are selected for CPD audit have not been able to complete their CPD target due to furlough, we will assess this on a case by case basis – and extend flexibility when appropriate.

[1] https://www.fca.org.uk/firms/training-and-competence/allowing-individuals-carry-over-continuing-professional-development-cpd-because-coronavirus