CPD requirements as a member of a professional body vs CPD requirements in terms of the FAIS Fit and Proper Determination
In the past few weeks, we have received several enquiries from our clients wanting to confirm whether the designation they hold with a professional body or the CPD points obtained as a member of a professional body automatically satisfies the CPD requirements in terms of the Fit and proper determination BN 194 of 2017.
It is common in various sectors, that professional bodies require its members to obtain a certain amount of CPD points or hours in order to remain a member or to retain the professional designation. Continuous Professional Development as a fit and proper requirement in terms of BN 194 of 2017 require Key Individuals and representatives to complete a number of CPD hours during the course of a CPD cycle. Failing to meet this requirement means a person is not fit and proper to act as a Key Individual or representative and, depending on the circumstances may lead to an individual being disbarred from rendering financial services.
What qualifies as a CPD activity in terms of the FAIS Fit and proper determination?
A CPD activity is an activity that is:
Accredited by a Professional Body;
Allocated an hour value or a part thereof by a Professional Body; and
The activity is variable.
It does not include activities towards a qualification or product specific training.
Does this mean that if you have a professional designation or comply with your professional body’s membership requirement for CPD that you will automatically comply with the CPD requirements in terms of FAIS Fit and proper determination? Not necessarily.
At this stage having a professional designation does not exempt you from complying with the CPD requirements in the Fit and proper determination.
In some instances the CPD activities undertaken, in terms of the membership requirements, may qualify as CPD hours in terms of the fit and proper requirements, but only if it complies with the requirements stated above for a CPD activity.
In a recent discussion with the FSCA, the FSCA confirmed that it is considering an amendment to the current Fit and proper determination to accommodate or recognise CPD points obtained in terms of a professional designation. What the proposed amendment exactly entails is still unclear but hopefully, the amendment will come into effect before the end of the CPD cycle on the 31st of May 2019. We shall keep you posted on the developments.