T&C Schemes – How to focus CPD on a seldom used activity


From 1st October last year firms who undertake insurance activities in relation to insurance based products (IBIPs) which include bonds, pure protection, general insurance activities, as well as insured pension contracts are, under FCA Requirements, required to include in their T&C Scheme the need to undertake a minimum of fifteen hours professional training or development per year for insurance based products. The scope includes all staff involved in insurance distribution such as advisers, supervisors, and also the person responsible for insurance intermediation. This can be either structured or unstructured CPD, and this can be incorporated within the annual CPD requirement of thirty-five hours. This is often referred to this as IDD CPD.

Fine, you might think, not an additional amount of CPD required, just a change in what the CPD requirements should cover. But that change might not be as easy to convey as you might think, or indeed, have discovered when trying to implement the change.

Probably a lot depends on a firms’ core business activities. A firm that has holistic financial planning at the heart of its business may find it quite easy to document CPD in relation to insurance based products, because it’s likely that those in the T&C Scheme will naturally cover this. But a firm who operates primarily as a wealth manager, concentrating on accumulating funds under management, is less likely to include insurance based products, other than pension contracts in the individual CPD activities, and it’s more likely that individuals would naturally attend investment-related seminars and workshops rather than those related to a seldom-used activity.

The point is to encourage the refreshment of past knowledge that may not have been used for some time in practice, or provide new knowledge, and not to just tick boxes.

Whilst an individual is responsible for their own CPD activities and records, any T&C Scheme, especially those that include CPD as a Key Performance Indicator, should monitor the individuals CPD and assist where necessary in acquiring and documenting the appropriate level and scope of CPD. Left to their own devices it’s quite likely that there will be individuals who won’t undertake activities relating to the new requirements, just as many of us who run T&C Schemes will acknowledge that sometimes whilst the CPD may have been undertaken, the physical recording of it is a “challenge” for some individuals.

So, if we run the T&C Scheme for a firm whose core business is that of a wealth manager, how do we get individuals within the scheme whose primary focus is on investment, to undertake IDD CPD? There’s probably two options: One would be to go down the “tell” route, but you might question whether that is an appropriate route given that the individuals are responsible for their own CPD? And if the firm has individuals who are not directly employed, this probably couldn’t be enforced anyway.

A better route would be to “encourage” the undertaking of IDD CPD. Consider, as a suggestion, that at the beginning of each calendar month all members of the T&C Scheme are provided with CPD “activity” relating to the required professional training or development. This could be in the form of a sourced test that is then scored and any areas needing development as identified could be covered in a training or coaching session, either by individual or perhaps as a group. Related articles could be extracted from the various industry news feeds and passed out for reading, with confirmation that it has been read by each individual. Why not invite a provider into the firms’ office to provide a presentation on one of the products in scope, or perhaps locate a video that does something similar? Also, there is nothing wrong either with encouraging individuals to study for and pass exams that count specifically towards IDD CPD. Even better is not to make these tasks compulsory. The point is to encourage the refreshment of past knowledge that may not have been used for some time in practice, or provide new knowledge, and not to just tick boxes.

Monitoring will be very important because this will indicate how successful or otherwise the encouragement has been in terms of engagement and action. It will also provide a means of checking against individual CPD Statements. A point worth noting here is that this being a relatively new requirement the chances of individuals specifically designating CPD as IDD when they record their CPD is probably quite low and thus there may be a need to be ask for amendments to entries in their CPD log for clarity.

Finally, what if the take up of the offered CPD activities is low or there comes a point in their CPD year where individuals are unlikely to achieve the required fifteen hours? You may wish to consider a training day where any deficit could be made up by attendance and participation. Ideally this should only be there as a back-up, and not used as a last resort, although hopefully this won’t not be needed if we can encourage individuals into being sufficiently “motivated” into accepting that by undertaking the monthly CPD tasks as issued, even if it’s unlikely that they will use the knowledge on a regular basis.




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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