Statement of CPD Policy (FASEA FPS004)
Approach to Continuous Professional Development (CPD)
ALEA Actuarial Consulting Pty Ltd is an independent consulting firm with an experienced team of actuaries, analysts and supporting staff dedicated to providing professional actuarial services and advice to a broad range of clients.
ALEA is committed to the ongoing professional development of its staff and specifically, its advisers.
ALEA aims to adhere to the CPD requirements of:
- the Institute of Actuaries of Australia (IAAust) Professional Standard 1 (PS1) “Continuing Professional Development (dated December 2017); and
- the Financial Adviser Standards and Ethics Authority (FASEA) FPS004 (dated January 2019) where applicable.
Members of IAAust must comply with PS1.
Authorised representatives under ALEA’s Australian Financial Services License (AFSL) must comply with FPS004.
ALEA’s CPD Year is a calendar year – 1 January to 31 December.
Approving CPD Activities
Our advisers may undertake their CPD in the following ways:
- Formal relevant education (provided by an education provider) including degree equivalent study to meet legislative requirements (such as bridging courses and approved degrees) and any formal qualifications and designations relevant to the practice of the financial adviser; to a maximum of 25 CPD hours per year
- Non-formal education including for the purposes of achieving a relevant professional designation, for the purposes of meeting requirements in specific financial advice provision (aged care, self-managed superannuation etc.) and for the purposes of accreditation in specific form of financial products relevant to licensing arrangements
- with acceptable/approved CPD platforms and content providers
- in-house training sessions/workshops (internally developed and/or arranged)
- attendance at professional developments days and workshops
- completing other professional development activities for example those provided by professional associations, product providers and other financial services industry participants
- professional reading – four hours per annum maximum.
At least 70 per cent of all professional development activities undertaken by our financial advisers must be approved by ALEA as the responsible Australian Financial Services Licensee.
CPD Activities Approval and Allocation of Hours
All training completed through approved platforms and with approved providers are automatically approved in accordance with their estimation of CPD hours.
All other professional development activity submitted for ALEA CPD approval will be assessed on a case-by-case basis by the Director.
To be approved the CPD activity must meet all of the following requirements in accordance with FASEA’s Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018 (Exposure Draft), the final determination and any subsequent amendments.
In summary, the FASEA’s determination stipulates that a qualifying CPD activity must:
- Be an activity which falls into the following CPD areas of:
- technical competence – designed to enhance participants’ technical proficiency and ability to develop and provide advice
- client care and practice – designed to enhance participants’ ability as a client-centric adviser
- regulatory compliance – designed to enhance participants’ understanding of legal obligations and compliance
- professionalism and ethics – designed to enhance participants’ capacity to act as an ethical professional
- general – designed to maintain and extend participants’ professional capabilities, knowledge and skills and other relevant developments not referred to above.
- Have sufficient intellectual or practical content.
- Primarily deal with matters relating to the provision of financial product advice.
- Be led or conducted by one or more persons who are appropriate, have sufficient standing, expertise, academic qualifications and practical experience.*
- Be designed to enhance the financial adviser’s knowledge and skills in areas that are relevant to the provision of financial product advice
* Does not apply to an activity that consists of professional or technical reading.
If the CPD activity covers more than one CPD area, it will only be allocated to the CPD area to which it predominately relates.
If the adviser conducts or leads the CPD activity; the number of hours spent conducting or leading the activity can be allocated to their CPD plan.
If hours have not been allocated by the CPD content provider, or content is developed in-house; approved CPD hours will be determined and recorded in accordance with the following broad guidelines:
- static content – as assessed and agreed
- interactive content – as assessed and agreed
- audio or face to face content – as assessed and agreed.
Provision of CPD Activities by appropriate persons or entities
All training completed through approved platforms and with approved providers is automatically approved as being provided by persons or entities that are appropriate.
All other CPD activities, required to reach the required minimum of 70 per cent approval within a CPD year, undertaken by our financial advisers, must be approved by the Director on a case-by-case basis.
The determination of the appropriateness of the entity or person providing the CPD activity will include consideration of the following factors:
- sufficient standing
- academic qualifications
- practical expertise
CPD Outcomes Evidence
All professional CPD content through approved platforms and with approved providers includes associated learning objectives and outcomes and these are automatically approved as evidencing outcomes of CPD.
When approving accredited CPD content; the Director must consider the learning objectives/outcomes of the CPD content, as they relate to the role of the financial adviser, prior to approving the allocation of hours to the advisers CPD training plan. This is in addition to assessing the appropriateness of the person or entity providing the CPD as outlined previously.
ALEA acknowledges that professional research and technical reading is an integral part of being an adviser. If an adviser undertakes professional reading as a part of their CPD, they must keep a record of the material read, provide a brief summary of the material (may be bullet points) and calculate the CPD hours as agreed with the Director.
Developing CPD Plans
The training needs of each adviser will be assessed when developing the annual CPD training plan. Considerations will include:
- the financial services the representative is authorised to provide
- previous training completed by the representative before and after they joined ALEA
- the adviser’s performance over the preceding year
- any recommendations made following an internal or external compliance audit
- any feedback received from their supervisor or manager
- any feedback or learnings from the dispute resolution process
- regulatory or business change which affects the advisers and/or the way they provide their financial services
- their knowledge and skill requirements with reference to FASEA’s Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018(Exposure Draft) and the final determination (as updated).
Example of CPD Plan
|CPD Category||Description||Min. CPD hours/year|
|1. Technical competence||enhances technical proficiency and ability to provide advice and strategies relevant to the personal circumstances of different type of retail clients||5|
|2. Client care and practice||enhances ability to act as a client-centric practitioner in advising retail clients||5|
|3. Regulatory compliance and consumer protection||enhances understanding of applicable legal obligations and compliance||5|
|4. Professionalism and ethics||enhances capacity to act as an ethical adviser||9|
|5. General||maintains and extends professional capabilities, knowledge and skills, including keeping up to date with regulatory, technical and other relevant developments not in an area referred to elsewhere in this table||16|
|Minimum CPD hours||40|
All CPD plans, including any plan amendments, will be provided to the financial adviser, in writing.
Monitoring of CPD Activities
ALEA will monitor the completion of CPD activities, and adherence to this CPD policy on a half-yearly basis. If the Director becomes concerned that an adviser is at risk of not completing the required CPD within the CPD year; they may direct the adviser to complete a certain number of CPD hours within a designated time frame.
Any adviser that does not complete the requisite CPD training plan within the CPD year will be reported to ASIC in accordance with ALEA’s reporting obligations. Any such adviser must complete the prior year’s training plan prior to commencing their new CPD year training plan, and may not be permitted to provide financial advice to retail clients until the prior year plan is completed in its entirety.
When an adviser has had a career break of a continuous period of two years or more, they are not able to resume practice as a financial adviser until ALEA has approved a CPD plan for the first year that is designed to address any gaps in their competence, skills and knowledge that may have arisen in that period.
ALEA may require the adviser to undertake specified CPD activities prior to providing personal advice to retail clients as a result of the career break.
ALEA may also require others who have had breaks of shorter duration to undertake specific CPD activities prior to providing personal advice to retail clients, for instance after a period of parental, disability or medical leave.
Advisers must keep records of their CPD for a period of seven (7) years from the end of any given CPD year. Evidence of CPD activities must be provided to ALEA upon request.
If an adviser leaves, they must provide ALEA with a copy of their complete CPD transcript as part of the standard termination process. The record must include all CPD activities undertaken throughout their time as an adviser with ALEA.
The records for each CPD activity should capture:
- Date of CPD activity
- Event/Activity (including name of provider/source)
- Detailed description of activity
- CPD Hours
- CPD Points (under IAAust)
- Accredited/non-accredited activities
In authorising relevant providers who have recently completed their Professional Year, given the extent of training undertaken during the Professional Year, ALEA may choose to pro-rata the CPD hours for the period between completion of the Professional Year and the end of the licensees CPD year depending upon a review of such training.
ALEA may choose to recognise the CPD undertaken with a previous licensee when authorising an existing relevant provider upon a review of such training and upon being provided with acceptable documentary proof of training.
Agreement to Comply
Upon their appointment by ALEA advisers will be supplied with a current copy of this policy and will be directed to other relevant documentation for their information and review.
Subsequent to their agreement to comply with this policy, and their obligations thereunder, the CPD Policy Agreement Form is to be signed by them and retained in their personnel files.
If an adviser believes at any time they may have inadvertently breached or failed to fully comply with the CPD Policy, this should be reported to the licensee without delay and no longer than three (3) days after they become aware of the breach or failure to comply.
Date: 29 March 2019