My ten cent worth on this debate
Here is the official definition from Board Notice 194 of 2017
"CPD" means continuous professional development;
"CPD activity" means an activity that is‑
(a) accredited by a Professional Body;
(b) allocated an hour value or a part thereof by that Professional Body; and
(3) verifiable, and excludes ‑
(i) an activity performed towards a qualification; and
(ii) product specific training;
"CPD cycle" means a period of 12 months commencing on 1 June of every year and ending 31 May of the following year;
FSCA FAIS Notice 86 of 2018
"CPD requirements" means, insofar it applies to representatives, the requirements relating to continuous professional development as set out in Chapter 4 of the Fit and Proper Requirements:
Chapter 4 of Board Notice 194 of 2017
(2) An FSP must establish and maintain policies and procedures on CPD that include:
(a) how the FSP, key individual and representative will‑
(i) maintain knowledge and skills that are appropriate for their activities and responsibilities;
(ii) update their knowledge and skills; and
(3) develop new knowledge and skills to assist with their current functions and responsibilities or functions contemplated in the future;
(b) training plans for each CPD cycle to ensure that CPD -
(i) is relevant and appropriate for the authorisation, approval and appointment of the FSP, key individual and representative;
(ii) addresses any identified needs, knowledge and skills gaps; and
(3) continually improves the professional standards and practices of the FSP, its key individuals and representatives.
(3) An FSP must‑
(a) within 30 days after the expiry of each CPD cycle, record in the competence register the:
- CPD activities of the FSP, its key individuals and representatives; and
- reduction of CPD hours of a representative as contemplated in section 34;
- calculate the total number of CPD hours completed by each person referred to in (a) as at the end of each CPD cycle;
- obtain and retain relevant supporting evidence of the CPD activities recorded in the competence register;
- record the dates of, reasons for and retain supporting evidence for, any decision of the FSP to reduce CPD requirements in accordance with section 34; and
- retain the evidence referred to in (c) and (d) for a period, not less than five years from the end of the CPD cycle concerned.
What is important to deduct from the definition is that:
- It must ensure you maintain knowledge and skills
- It must be appropriate to their activities
- It must be appropriate to their responsibilities
- Update their knowledge and skills
- Develop new knowledge and skills
- Assist with their current functions and responsibilities
- Prepare for future functions
- Must form part of Training plans
- Relevant and appropriate for the authorisation, approval and appointment of the FSP, key individual and representative.
- Addresses any identified needs, knowledge and skills gaps
- Continually improves the professional standards and practices
Now my concern:
As a Certified Financial Planner Professional (CFP®), we need to do 35 CPD hours/credits of which:
- 20 hours must be knowledge related (verifiable)
- 5 hours Ethics-related (verifiable)
- 10 hours the reading of industry articles. (non-verifiable)
Now if we go back to the FSCA definitions it seems clear that the emphasis is on knowledge, skills, appropriate to activities and responsibilities. Also maintaining and updating your KNOWLEDGE and skills. Therefore reading articles and opinions of others, although interesting and contributing to the debate of professionalising the industry is not per se training, and I cannot understand how that necessarily would be able to fit into and assist with identifying needs, knowledge and skills gaps. I also cannot see how reading articles would assist in the relevant and appropriate training for the authorisation, approval and appointment of the FSP, key individual and representative.
To increase the confusion currently...
What is Professional Credits and FAIS Credits
This is where the confusion comes in. I have quoted from the FSCA Board Notice 194 of 2017 and FSCA FAIS Notice 86 of 2018.
Nowhere does it refer to Professional Credits or FAIS Credits. This is an invention of the Professional Bodies and not an official view of the FSCA.
Especially the IISA created a distinction between Profesional Credits for their members and FAIS credits for the other representatives who are not members. All of a sudden a new terminology pop up called FAIS Credits, therefore FANews correctly states in communication I received, that there is no specific definition for FAIS Credits, as it only exists in the minds of the Professional Bodies.
Bottom line is that all must comply with CPD Credits and definitions according to the requirements set out in Board Notice 194 of 2017, especially Chapter 4 of the Board Notice. The FPI makes the distinction between Knowledge and Ethics credits for their members, with additional reading to achieve the 35 credits they must obtain. But the reading of articles is non-verifiable credits for the purpose of maintaining your Professional CFP® status.
All the representatives and Key Individuals and FSPs must comply with Board Notice 194 of 2017 and FSCA FAIS Notice 86 of 2018. Therefore my opinion is that one needs to be careful when the content does not align with Chapter 4 requirements of Board Notice 194 of 2017.
So be careful of falling in a trap of taking the easy way out. The whole movement around the changes in our Industry is to improve the quality of education and advice given to our clients. We are aiming to PROFESSIONALISE the industry.