|Any introduction should include:
The job description or role profile is the foundation for recording competence. You should state:
|Approved persons/certification regime||
This should set out the recruitment process prior to a conditional job offer:
In addition, when the applicant completes the application for authorisation, it should set out:
|Others||As per Approved Persons and those subject to the Certification Regime above, your aim here is to ensure that staff are suitable. However, the referencing and checking may be less onerous|
New starters should be briefed about your organisation as part of the induction. For example:
This applies to everyone and can be formal or informal. For most staff this is where you will explain how they will achieve and be assessed as competent on an ongoing basis. For example, through your annual appraisal or certification process.
All new starters will need appropriate training, either on a face-to-face basis, or more commonly by eLearning.
This training will also need to be repeated on a regular basis to ensure knowledge is retained and new policies and processes are shared as part of maintaining competence.
|New to the organisation - Financial Advisers/Investment Managers/Mortgage Advisers/Certificated roles|
Everyone will need some training to be assessed as a competent individual for your firm. For example, they will not know your procedures and forms for giving advice.
If an examination is required to achieve competence, this section should state:
In addition, it will set out:
|Initial competence sign-off||
This section should state:
|Competent Advisers/Investment Managers/Mortgage Advisers/Certificated Roles|
|Definitions||Individuals who have been signed off as competent by your organisation.|
|Long-term absence||What happens on their return to work after a long absence, e.g. 6 months or more?|
|Short-term absence||What happens if they are away for a shorter time to make sure they remain competent when they return?|
|Definitions||Who can supervise advisers.|
What level of supervision is appropriate and when. For example:
|Training for supervisors||
State what essential knowledge and skills are required for supervising others. For example:
This information should appear in more detail in the role profile.
State whether an external examination is required as well as how the training will be delivered, when and by whom.
This should state:
|Maintaining competence (CPD)|
In what ways will competence be maintained? How will the essential elements be addressed? For example:
Who is responsible for maintaining competence? For example, will your organisation ensure that appropriate training and testing is delivered, or is it the responsibility of the individual? (keep in mind the FCA’s obligations clearly fall upon the organisation).
Will your organisation apply for an individual’s Statement of professional standing or will that be left to the individual?
|Advisers/Investment Managers, Mortgage Advisers, Certificated Roles||Specific standards, e.g. an annual test of generic knowledge post-budget.|
|Supervisors||Specific standards for supervisors, if any.|
|CPD hours||Those individuals in regulated roles that give investment advice need to complete at least 35 hours of CPD per year, of which 21 hours must be structured. There is no mandatory number of hours for other roles but you may want to apply this across the board or set other levels.|
|By staff||What records should staff hold themselves. For example, copies of tests, appraisals, and a competence certificate?|
What key records will be held centrally by your organisation to evidence compliance. For example:
|Reporting and risk controls|
The controls you have put in place to ensure that people follow the procedures. For example:
State also who is responsible for doing this and to whom any reports/MI is sent (the Approved Person responsible for overseeing the Scheme).
|Reporting to the FCA||
State the data that will be collected and by whom in order to make returns to the FCA. For example: