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What does the end of ‘gap-filling’ mean for advisers?

Relevance of older qualifications is being put under a microscope

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The Chartered Insurance Institute (CII) recently informed its members it will be phasing out its ‘gap-fill’ programme, which will come to an end in August 2021.

The scheme allowed financial advisers applying for a statement of professional standing (SPS) to use continuing professional development (CPD) as a way to bridge any missing content between existing and new exams for level 4 qualifications.

The measure was introduced when the Financial Conduct Authority (FCA) rolled out the Retail Distribution Review (RDR) in 2013.

But the CII said that a recent review found that the qualifications allowed under gap-fill “are beginning to be outdated”, so it decided to end this option.

Keith Richards, chief executive of the Personal Finance Society, said: “The gap-filling option effectively managed risks to consumer harm, while enabling a fair transition to RDR qualification requirements for advisers who have, for example, been continuously absent from work.

“However, given the length of time that has elapsed since the introduction of the RDR, it is now appropriate to end this transitional approach and apply appropriate standards of recognition of prior learning to professionals who have qualifications that do not fully meet the FCA’s criteria for advising on retail investment products.

“As a result, we will be ending the ‘gap-filling’ CPD process as a route for advisers to attain a statement of professional standing from the end of August 2021.”

Shared move

But the CII is not the only industry body to come to this conclusion.

The Chartered Institute for Securities & Investments (CISI) informed its members in May that its gap-filling will come to an end by 31 December 2020.

It told International Adviser a reminder had been sent to its members last week about the measure.

“CISI has taken the decision to withdraw gap-fill for our exams as it is no longer appropriate to fill the gaps in qualifications in this way as a result of changes made to the exam standards by the FCA.

“If you wish to use gap-fill you must complete and log any gap-fill with CISI by 31 December 2020.

“The December sitting of our Private Client Investment Advice and Management qualification (PCIAM) was to be the last time you could use gap-fill with PCIAM.

“As the December exams have been postponed until February, the February sitting will now be the last time you can use gap-fill with PCIAM, but you must still complete and log your gap-fill with us by 31 December 2020.”

Industry consent

Financial advisory firms in the UK agree with the trade bodies’ decision, with the number of advisers affected expected to be very small.

Ban Wright, director of strategic development at Tenet, told IA: “We appreciate that, for those affected, it means some more formal study in what is already a difficult environment to operate in.

“The regulated landscape has changed so much in recent years and we would agree with the CII that older qualifications may no longer be as relevant as they once were, and advisers have had seven years since RDR to bring their qualifications to the required standard.

“It’s important to remember though that an exam is only proof of knowledge at a set point in time, which makes the ongoing CPD so important for advisers.”

Edward Grant, director of technical connection a St James’s Place, agrees.

He told IA: “The announcement to end gap-fill in August 2021 is totally understandable.

“It is great to see that the CII have given time for members to complete the gap-fill, which is important for returners and non-advising teams that have versions of the diploma that were relevant and appropriate at the time they completed them.

“SJP will be communicating the changes across the partner support specialists who are likely to be most impacted.”

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