20 January 2011

FSA: Qualification gap-fill

Advisers who already hold, or who are in the process of completing, qualifications marked with a ‘b’ in the qualifications list in the FSA Handbook can use qualification gap-fill to meet the qualification requirements. This does not mean more exams but structured learning to complete any gaps. A suitable form of structured learning needs to be decided. For example, e-learning packages, conferences, seminars and workshops. In some instances, an exam can be the most suitable form of gap-fill.

The FSA has estimated that advisers who hold one of these qualifications will need to complete around 16 hours of gap-fill, with the main focus on ethical standards.

All advisers must gap-fill on three key modules. They are:

• financial services, regulation and ethics;
• investment principles and risk;
• personal taxation.

Gap-filling will be different for every adviser, but some points to be considered are:

1. Identify the gaps based on the three modules above and the specialist activity being carried out, of which there are five types. This may be one or several of the following:

• advising on packaged products
• advising on and dealing in securities
• advising on and dealing in derivatives
• advising on pensions and retirement 

2. If other higher-level qualifications are held then check the syllabus for that qualification to see if any of the required content has been studied. This can be used as evidence for gap fill. However, the FSA stresses that it thinks it unlikely that existing level 3 qualifications will meet the learning outcomes required for gap-filling, because these will only have required the adviser to apply facts and principles in a methodical way, whereas gap fill requires the adviser to analyse, explain and apply technical knowledge.

3. Check old CPD records to see if any structured activities have been carried out that meet the FSA's requirements. This can also be used as evidence for gap fill.

4. Identify what structured learning will be undertaken for the remaining gaps. If structured CPD is not available to fill the gap identified, the gap may be completed by reading suitable material. The FSA expects that this would be for a minority of gaps. As all gap fill activities must be capable of being verified by an accredited body, it is up to accredited bodies to determine what they are able to verify independently. It is likely that in the minority of occasions that reading is used, accredited bodies will require that the effectiveness of that reading is tested so that there is evidence that can be verified.

5. Gap-fill must be undertaken by the end of 2012, but this includes leaving enough time to apply to an accredited body to validate the gap-fill and to have a statement of professional standing (SPS) issued.

6. The adviser must be able to demonstrate that s/he has filled the gap. This can be evidenced by detailing the target learning outcome, recording the learning activity completed and how the activity has given the knowledge needed. If the Qualification Gap Fill template is completed or a gap fill certificate from the qualification provider obtained, then the adviser should be able to take this to the chosen Accredited Body to obtain an SPS.

In June 2011, the FSA will be consulting on a list of accredited bodies. Some of these bodies have already stated publically that they have applied for accreditation. Any member of a professional body should ask whether that body is applying for accredited status. One of their roles will be to ensure that their members meet the FSA's professional requirements and issue an SPS. In order that an Accredited Body can issue an SPS, it must check 100 per cent of qualification gap fill because this is effectively an alternative means of meeting the new qualification standards.

Further information:

• Gap fill template
• List of RDR qualifications
• One-minute guide – Professionalism
• Factsheet - Professionalism

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