FCA T&C – How does a T&C person maintain and demonstrate competence


Training is teaching either yourself or others, and generally evolves either from identifying one’s own needs or those of others, or from a pre-planned program of delivery. Its aim is to improve skills and knowledge that relate to specific competencies.

Competence, according to the Oxford English Dictionary, is “the ability to do something successfully or efficiently”.  The definitions of “success” include accomplishing a result and for “efficient” include having requisite knowledge, skill, reliability and capability.

So how does one define a “T&C person”? Looking at the FCA rules a  scheme itself can be broken into three core elements: Supervision, Training, and Monitoring.  Firms, often the smaller ones, appoint a single individual to take on all the responsibility to deliver all three elements of the scheme. Other, larger firms are more likely to split the delivery into those running the scheme (Monitoring) and those delivering the requirements of the scheme (Supervision and Training).  Whichever it is, any individual involved in the scheme needs to demonstrate and maintain competence.

A firm may employ individuals who would, for example, provide the Monitoring element through carrying out administrative tasks such as collating and recording all inputs on behalf of the scheme. These individuals are likely to provide management information, check CPD records, and ensure that certain requirements such as annual testing and fit and proper declarations are completed, and probably even remind advisers that their SPS renewals are due. They are assessed on their own competence, they are still “T&C people”, but they are unlikely to be subject to the requirements of the scheme itself.

Monitoring also extends to other areas, such as Quality Assurance. Here a firm may employ individuals to carry out specific tasks such as file reviews. Again these are “T&C people”, but unlike their more administrative colleagues, they will need to fulfil certain competencies because the scheme would require these individuals to have the relevant qualifications and up to date knowledge.

Individuals who Supervise or provide Training would be subject to the scheme’s requirements because, like some of the monitoring tasks, these also require individuals who work in a face to face environment, to have both the relevant qualifications and up to date knowledge so that in carrying out the tasks they are on at least equal terms with the scheme members that they supervise or train.

A well-organised supervisor or one who is supported by a monitoring team is less likely to miss a key date or competency than one who deals with everything themselves.

Training also needs to encompass the scheme’s competency requirements. Some larger firms may have their own training departments. Smaller firms may choose to task certain individuals, perhaps the Supervisor, with providing the training. Individuals who train need to be competent themselves to train others, and the scheme will define the level of competency needed for both.

Supervision usually falls to somebody in charge of others who fall within the scheme requirements. This might, for example, be a Sales Director or perhaps the Head of Para-planning. In some firms the T&C Supervisor might be an individual heading up a team of people, perhaps a team of advisers, but who may also actively provide advice themselves. These individuals are therefore subject to two sets of competencies, those for the Supervision of individuals and those for carrying out their own advisory work.

So how does a T&C person maintain competence? The key is quite simply good organisation. The scheme sets out what each individual needs to do to maintain competence. So you might think that if it’s just a question of ticking boxes, and at least the maintaining element should be relatively straight-forward to fulfil.

It’s probably fair to say that the more responsibilities that the individual has, and the busier their workload, the chances are that they are less likely to keep on top of their competencies, for any number of reasons. For example, if the individual is in a Supervisory position only, then the scheme’s requirements would, amongst others, include maintaining knowledge, recorded through CPD. Other competencies would include the Supervisors’ spans of control; perhaps they might have six direct reports being four advisers and two para-planners, all of whom might be included in the scheme and therefore the Supervisor would be responsible for maintaining not just their own competence, but also ensuring that all their direct reports maintain theirs as well. A well-organised Supervisor, or one who is supported by a monitoring team is less likely to miss a key date or competency than one who deals with everything themselves.

Organisation is even more paramount where the Supervisor is responsible for multiple functions, for example they may be the “Head of” with many responsibilities in addition to themselves and their direct reports, or if they are a Supervisor with a business requirement to give advice, which only serves to expand the areas where they are required to maintain competence.

Demonstrating competence is a matter of application. For example a Supervisor may need to organise assessments for direct reports in order to demonstrate a Monitoring and possible Training competency. Yet even conducting an assessment isn’t without its own challenges since starts with collusion between two sets of diary commitments to get a date when the competency, for both individuals, can be carried out.

There are also the T&C specialists who transfer their skills from one firm to another. These skills might include Monitoring tasks such as file reviewers, or assessments of individuals demonstrating competence. Typically these would be contractors who have to demonstrate and maintain their own competency through meeting that client’s own scheme requirements through initial and then regular assessments.

Organisation is a matter of good forward planning. Supervisors should consider booking all their 121 meetings six to twelve months in advance in their own and their direct reports’ diaries. Don’t forget to book the meeting spaces too! Individuals who also have Monitoring responsibilities should plan and stick to a robust diary structure across a twelve month period. As the saying goes, “you have to be in it to win it”, so a T&C Person has to maintain their competencies before they can demonstrate them.

The T&C persons’ world is actually quite a complex place, depending on what level of tasks and responsibility an individual holds. Maintaining and demonstrating competence can be thwarted at any time without having the skills to organise the competency and then applying other skills to that competency.


About Author

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I am a highly-versatile and forward thinking management professional with a history of successful delivery across more than thirty years’ in the Financial Services Industry. Core skills include assessing, training, coaching, process design and implementation, specialising in people, processes, and procedures within a Training & Competence or Learning & Development framework. Periodic writer for T-C News.com

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