With the latest changes announced in Board Notice 194 of 2017, which relates to the revised Fit and Proper requirements, there are some adjustments to be made in the Continuing Professional Development (CPD) record keeping process.
The only requirement stipulated in the Board Notice, relating to professional bodies, is the requirement that CPD activities are rated and approved by a South African Qualifications Authority (SAQA) recognised professional body.
The verification process
As part of this approval process, the professional body should also verify and confirm that the CPD partner can verify the identity of participants of an activity, and the completion thereof.
The verification of attendance and completion of an activity can take place in different forms, depending on the delivery method of the activity, as well as the technology available to the CPD partner. In considering the delivery method, if an individual attends an event, he or she may need to:
If the activity is an online webinar or has an online assessment the individual’s profile needs to be authenticated, and his or her completion result would provide verifiable evidence of completing the activity.
In both instances, whether face to face, online or a blend of both, the individual still requires some form of documentation to provide evidence of his or her CPD achievement.
A record of achievement
Some professional bodies may provide a service where these activities can be recorded, however, most professional bodies record CPD for their members only. So, what if the individual is not a member of the approving or any professional body?
In this instance, the CPD partner would need to provide the individual with a record of achievement, or attendance and completion. The record should contain information regarding the activity itself which should include the activity title, activity date, CPD partner, the CPD rating granted and approving professional body.
This document could be system generated in the case of online activities or provided in a different format by the CPD partner, post the event.
As an authorised representative or key individual, the onus is now on the individual to provide this record to his or her key individual or Compliance Officer, for collation and recording on the competence register. Financial Service Providers (FSPs) could have an internal system or process by which this record keeping can be facilitated, provided such a process is communicated to the affected representatives. Some companies, for example, have inhouse systems which facilitate the advertising of upcoming events, create or plan personal development and upload documented evidence of the individual’s achievements for reporting, management approval and record keeping purposes.
Compliance Officers and key individuals of FSP’s are responsible for collating the CPD records submitted and recording the relevant details on the competence register for submission to the Financial Sector Conduct Authority (FSCA).
Should a representative or key individual be a member of another professional body other than that which approved the CPD event, the person can submit the same records to their relevant professional body for CPD purposes.
Professional body agreement
There is an inter-professional body agreement that was signed by many of the financial services related professional bodies, that they would accept CPD rating and approval by other professional bodies. This is because all SAQA recognised professional bodies are benchmarked against the same criteria at SAQA and granted a status against the benchmark. Therefore, it would be improper for professional bodies to question other recognised professional bodies’ processes and systems.
There is no need for a professional body to record or track CPD hours for non-members for FSCA purposes.