SAIFM POLICY AND PROCEDURE: CONTINUOUS PROFESSIONAL DEVELOPMENT (CPD) PROVIDER ACCREDITATION AND CPD PROGRAMME APPROVAL IN TERMS OF BOARD NOTICE 194 OF 2017 UNDER THE FAIS ACT, 2002

INTRODUCTION

SAIFM is a SAQA recognised professional body and was invited by the FSCA to participate in a working group that focusses on the effective implementation of the fit and proper requirements for financial services providers (FSPs), key individuals and representatives as determined in Board Notice 194 of 2017 (BN), in terms of the Financial Advisory and Intermediary Services Act, 2002 (FAIS Act).

In this context, SAIFM is committed to supporting the FSCA in its objective of raising the level of professionalism in the financial markets. The FSCA’s objective is in line with SAIFM’s Charter objectives of promoting professionalism and integrity in the financial markets and will include corporate membership, which includes the obligation to comply with the SAIFM Charter and Code of Conduct. SAIFM’s role as the recognised professional body for the financial markets will be further enhanced by this initiative. In this regard it is important to distinguish between CPD requirements imposed on SAIFM members as approved by SAQA and CPD activities offered by accredited CPS provider companies for their employees under the BN, who may or may not be members of SAIFM.

SAIFM has set up this policy and procedure to, within the constraints of various regulatory requirements –

accredit companies operating in the financial markets that are registered under FAIS Act as CPD providers by evaluating their capacity to deliver CPD programmes; and
approve each programme applied for and that comply with the prerequisites for approval.

Approval as a CPD provider is a precondition for the approval of any CPD programme.

CPD provider accreditation will be valid for a period of one year from date of approval calculated from date of accreditation, unless renewed. Approval of each programme applied for and approved will be valid for a period of one year from date of approval unless renewed.

While every effort will be made to provide an effective service to enhance the ability of financial market participants to comply with BN 194 of 2017 and to assist the FSCA to attain its goal of ensuring proper CPD implementation under the FAIS Act, SAIFM cannot guarantee that CPD offerings by companies will be of the desired quality nor that they will comply with the requirements of Chapter 4 of the abovesaid BN. That will remain the ultimate responsibility of the accredited CPD provider.

CONTEXT

The purpose of CPD is to promote that FSCA licensed financial services providers, key individuals and representatives maintain the professional competence necessary to provide high quality service to financial customers and investors. CPD is learning and development that takes place after completion of the initial licensing requirements in terms of Board Notice 194 of 2017 and by means of which FSCA licensed FSPs, key individuals and representatives maintain and develop the competencies to continue to perform their licensed role competently.

CPD is intended to provide continuing development of

professional knowledge
professional skills
professional values, ethics and attitudes; and
competence achieved during the initial licensing requirements

The purpose is to enable members to continue to perform competently within their professional environments and chosen FSCA licence/s and to adhere to the SAIFM Code of Conduct.

POLICY OBJECTIVES

The objective of this policy and procedure is to provide guidance to financial market participants which are licenced under FAIS with regard to the requirements –

to become a SAIFM accredited provider of CPD for purposes of the fit and proper requirements for FSPs, representatives and key individuals in terms of BN 194 of 2017; and
to apply for approval of any CPD programmes it wishes to offer to ensure competence of the FSP, key individuals and representatives.

POLICY REQUIREMENTS

SAIFM currently only registers FSPs who provide CPD to their staff and clients.

Applicants’ responsibility

Initial application

Complete the SAIFM application form.
Provide all the supporting documentation required.
Pay the accreditation fee as stipulated by SAIFM and programme approval fee.
Deliver the CPD programme according to the description, standard and quality indicated the application.
Ensure that attendees meaningfully participate in the programme to ensure enhanced knowledge and understanding as per section 32(1)(c) of BN 194 of 2017.
Provide a copy of the relevant portion of the competence register to SAIFM upon request.
Agree to adhere to the SAIFM Code of Conduct.

Renewal application

Apply for programme renewal at least 2 months before the expiration date, indicating if and where the programme was altered or improved.
Pay the SAIFM renewal fee upon application.
Deliver the CPD programme according to the description and quality as stipulated in the application and if amended, as amended.
Ensure that attendees meaningfully participate in the programme.
Provide a copy of the relevant portion of the competence register to SAIFM upon request.
Agree to continue to adhere to the SAIFM Code of Conduct.

SAIFM’s responsibility

Assess the application for approval as CPD provider once the application form, supporting documents and application fee has been received.
Assess the application for approval of a particular programme once the application, supporting documents and application fee has been received.
Respond to all applications within a reasonable time to confirm whether an application was or was not successful.
Provide a confirmation of programme accreditation for the period granted.
Assess any resubmission upon receipt of recommended changes to the documentation and payment of a resubmission fee.

MEASUREMENT

BN 194 of 2017 requires that CPD must be verifiable and allocated an hour value or part thereof by a professional body and exclude activities performed towards a qualification and product specific training. To enable SAIFM to verify the nature of CPD training and the hourly allocation, an application for approval of a programme must therefore include –

Date of CPD activity
Description or title of activity
Type of activity, for example course, e-learning, face to face training
Duration (expressed in hours or quarter-hour increments)

MONITORING OF CPD

An approved CPD provider must upon request provide a copy of the relevant portion of the competence register in terms of section 32(3) of the BN that indicate the CPD activities relevant to SAIFM approval which includes the relevant information under measurement above as well as such other information as SAIFM may need to fulfil its obligations in terms of monitoring CPD.

TERMINATION OF ACCREDITATION OR APPROVAL

The accreditation of a CPD provider or approval of a particular programme will lapse upon expiry of the period for which accreditation or approval was granted, unless renewed.

Should a CPD provider no longer comply with the requirements for accreditation, SAIFM may give notice of 14 (fourteen) business days that the CPD provider must rectify or provide a plan for rectification acceptable to SAIFM. If not, SAIFM will be entitled to revoke the accreditation. No fees will be refundable. A CPD provider will be entitled in such a case to re-apply for accreditation but in such a case the full fee will be payable.

Should a CPD programme no longer comply with the requirements and the agreed standards for approval of a programme, SAIFM may give written notice of 14 (fourteen) business days that it must rectify the programme or provide a plan for rectification acceptable to SAIFM. If the absence of such a rectification or acceptable plan, SAIFM will be entitled to revoke the approval in which case the CPD provider will not be allowed to claim CPD points for such programme.