The Financial Services industry seems to have come to grips with the Fit and Proper Continuous Professional Development (CPD) requirements of BN 194 of 2017 and FAIS Notice 86 of 2018, but the same cannot be said for the Class of Business (COB) requirements of these same Notices. As we are already well into the new CPD cycle, which commenced from 1 June this year, it’s essential to get to grips with what is required, and soon.
COBs are one of the four current pillars of competency relevant to any new representative (rep) of an FSP employed after 1 April 2018, or to an existing rep in respect of any additional license categories. COBs must be completed within a year of that rep’s Date of First Appointment (DOFA) or within a year of the DOFA of the relevant license category.
It is crucial to note that COB competency requirements will only be met if they are provided by an accredited training provider (i.e. one registered with INSETA for example). But there is currently confusion as some training providers are offering CPDs on the subject matter of COB training and it is important to note that in such instances, you will only be provided with CPD hours, but not be meeting the COB requirements of Fit and Proper CPDs. Confusion can arise and it’s important to keep an eye that your reps are staying on top of their compliance requirements.
If you aren’t sure whether the CPD certificate you are assessing meets the CPD requirements of the abovementioned notices, here is what to watch out for. As a rule of thumb, the following must appear on the CPD certificate:
• Verification by a professional body as evidenced by their stamp (for example INSETA, the FPI or SAICA to name a few)
• The full name and ID of the rep
• The number of hours that are granted for attendance of the seminar or the test written
• The date of the seminar or test
If you are still unsure about it being either a CPD or COB certificate, you need to do further checks, such as ensuring that you obtain proof of training via a registered external accredited training provider.
FSPs have a duty to debar reps that fail to meet any Fit and Proper competency requirements. It’s a risk to your business otherwise, particularly if any complaints arise against a rep that was not Fit and Proper at the time of giving the advice, as there would be severe ramifications for the FSP in this case.
Working within the rules of compliance with Fit and Proper is always the best way for your business. As there are many aspects to keep in mind and easy ways to get confused, it may be a good idea to seek external compliance support to assist.
Get the latest issue of FAnews