Those who love record keeping will be elated by the new requirements contained in Board Notice 194 of 2017.
“A FSP must establish, maintain and update on a regular basis a competence register in which all qualifications, successfully completed regulatory examinations, product specific training, class of business training and CPD of the FSP, its key individuals and representatives are recorded.”
A FSP, key individual and representative must have adequate, appropriate and relevant skills, knowledge and expertise in respect of the financial services, financial products and functions that it performs in order to comply with the minimum requirements contained in BN 194 of 2017, and maintain such competence.
The FSP must be able to demonstrate and record that it has evaluated and reviewed, at regular and appropriate intervals, the competence of its representatives and key individuals and has taken appropriate action to ensure that they remain competent for the activities they perform. It also has to ascertain the appropriateness of the training and CPD, so choosing the cheap and easy route may turn out to be quite costly in the long run.
What needs to be included in the Register?
A FSP must establish, maintain and update a competence register, within 15 days after the training has occurred, in which the following is recorded:
- all qualifications,
- successfully completed regulatory examinations,
- product specific training,
- class of business training and
All such information and documentation relating to the training must be retained for a period not less than five years.
The FSP is obliged to provide confirmation, on request, to a product supplier that it, or its representatives have obtained the requisite class of business and product specific training.
FSPs are also obliged to provide training record information to other FSPs where, for example, it is required to for appointment purposes.
At Moonstone we are currently field testing a Fit and Proper Tracker system which will do far more than merely act as a record of activities. This should be good news to the other 99% who are not overly fond of paper work.