CU CPD Scheme. Regulations & Guidance

Transcription

1 CU CPD Scheme Regulations & Guidance August

2 Contents CPD and the Minimum Competency Code (MCC)... 4 Credit Union Core Services... 4 CU CPD and Fitness & Probity... 4 CU CPD and Pathways Qualifications... 5 The CU CPD Scheme... 7 CU CPD Requirements... 8 Pro Rata Adjustment of CPD Hours... 9 Relevancy Requirements for CPD... 9 CU CPD Streams... 9 Where to Gain CPD Hours Accreditation of CPD Events Record Keeping Annual Audit Annual Return of CU CPD Hours Shortfalls Removal from the CU CPD scheme Appeal of Decision to Remove from Scheme Reinstatement of CU CPD Membership and/or designation Fees for CU CPD membership Communications Ten Frequently Asked Questions 21 Some Terms Explained

3 Introduction The on-going training and up-skilling of all credit union personnel has always been key to the success of the credit union movement. CU CPD has been devised as a means by which all credit union personnel can gain access to up to date training and information to ensure that they remain well informed in the operations and good governance of the credit union. At present two categories of credit union officer must undertake CPD those with a qualification that includes a CPD element, i.e., Pathways, ACCUP, QFA or CUA holders, and those in the Republic of Ireland who were originally grandfathered by their credit union under the terms of the Central Bank s Minimum Competency Requirements (MCR) of However, the training and competence of credit union personnel is now under increased regulatory scrutiny, with the Central Bank (ROI) involvement in the Fitness & Probity standards for credit union officers and in Northern Ireland the FCA s Training & Competence regime. CU CPD membership for all board members, key committee members, managers and staff will provide a means for credit union personnel to help meet and prove their knowledge and competence in this new environment. These guidelines aim to outline the CU CPD scheme and how it applies to credit union personnel. This is an important document that should be read and fully understood by all CU CPD members. 3

4 CPD and the Minimum Competency Code (MCC) According to the Central Bank s (ROI) Minimum Competency Code 2011, anyone providing advice to consumers on retail financial products, or arranging or offering to arrange retail financial products for consumers and to the exercise of specified functions are required to be an accredited person. Importantly for credit unions, this only applies to individuals who offer insurance services, such as repayment protection insurance and travel insurance, to credit union members. (Loan protection, life savings and death benefit insurance are not covered by the MCC as they are not direct member pay insurances.) An individual can achieve the accredited person status through either: 'grandfathering' (confirmed by their credit union in 2007 based on having four years prior experience at that time) or obtaining a Central Bank recognised qualification. This recognition currently includes the Pathways Diploma in Operations, ACCUP, QFA, CUA & CIP qualifications. An accredited person then has to complete a number of CPD hours every year. Again, for credit unions, only insurance activities are currently covered by the MCC. Credit Union Core Services At present the credit union core products of savings and loans do not fall under a minimum competency standard. It is possible that this may change in the future as credit unions will be subject to some form of regulation in these areas through the extension of the MCC or Fitness & Probity Regime. At such a time it is likely that most credit union staff in the Republic of Ireland will then fall within a competency regime and be required to take CPD. At present a mandatory competency regime does not apply for Northern Ireland credit union personnel, however best practice and the recent regulator transfers will place more emphasis on the whole area of training & competence for Northern Ireland based credit union officers, and membership of a CPD scheme should help to show on-going competence. CU CPD and Fitness & Probity The Central Bank s Fitness & Probity regime for credit unions commenced August 1 st It requires all credit unions with in access of 10 million 4

5 in assets to establish and document the fitness and probity of those officers who hold what the Central Bank terms controlled functions (CF s) 1 within the credit union. In addition the Chair and Manager are deemed Pre approved Controlled Functions (PCF s) and will have to have their applications for these positions vetted by the Central Bank before taking these posts. The Central Bank views relevant training and qualifications as a primary method for any individual of demonstrating their competence and capability under the standards of Fitness and Probity. However, unlike the Minimum Competency Code, it does not specify a compulsory qualification or membership of a CPD scheme which must be completed by those looking to hold a PCF or CF role. Similarly, the former FSA s Approved Persons Regime required certain standards of key personnel within the credit union but did not go as far as to mandate particular qualifications or CPD membership. 2 Both the Pathways programmes and the courses provided under the CU CPD scheme are specifically designed to equip credit union officers with the necessary competence and capability to carry out their roles. Participation in the CU CPD scheme will help to enhance volunteer skills and knowledge and will give the credit union the benefit of that knowledge and understanding in the decisions that it makes. It may also go some way to demonstrating achievement of the required standards under these new regulatory requirements. It is likely that in the absence of other relevant qualifications or experience that the gaining of a relevant qualification and/or the maintaining of CPD will be an important element in demonstrating fitness & probity. The ILCU therefore strongly recommends that credit unions encourage their officers currently holding, or planning to hold, CF and PCF roles to undertake a Pathways programme and/or join the CU CPD scheme as a means of demonstrating their competence and capability in order to meet the standards of fitness and probity. CU CPD and Pathways Qualifications Those who have successfully completed Pathways qualifications will be entitled to claim a designation. In order to maintain the designation they 1 CF s include functions that exercise significant influence and functions which related to ensuring, controlling or monitoring compliance within the credit union. 2 Under the new FCA and PRA regimes the whole area of approved persons is being looked at with a view of significantly changing this regime. Further details on the FCA website. 5

6 will also be required to join the CU CPD scheme and complete their annual CPD training requirement. Note: Those who have completed the ACCUP qualification were awarded the designation R-CUP. This designation remains in place and is recognised under the Central Bank s MCC. The new Pathways credit union designations are listed below: Pathways Qualification Certificate in Operations Certificate in Governance Diploma in Operations Diploma in Governance Designation Awarded CU Ops. (affiliate) CU Gov. (affiliate) CU Ops. CU Gov. Comments Forms the first part of the Diploma in Operations. Recommended for new officers employed by the credit union or as the first qualification for existing operational officers. Meets a new director s requirement for induction training. Recommended for any officer currently holding or planning to hold a CF governance role under fitness & probity, (e.g. board or key committee members). Required by those who fall under the Central Banks MCC requirement through the offering of Insurances in the credit union. Recommended for any officer currently holding, or planning to hold, a CF or PCF operational role, (e.g. compliance or risk officer, manager). Recommended for experienced volunteer officers looking to hold the PCF position of Chair or other senior CF governance roles, particularly in larger credit unions. Membership of the CU CPD scheme is also open to credit union officers who may not yet have completed a designated qualification. This may include those officers originally grandfathered under the MCC, or those who may wish to show standards of fitness & probity through membership of a CPD scheme. Such members may avail of the scheme as ordinary CU CPD members and will benefit from the advantages of scheme membership including access to free e-learning courses. 6

7 The CU CPD Scheme ILCU has implemented a continuing professional development (CPD) regime for all credit union staff and volunteers to assist them in meeting their training and development requirements. The following credit union personnel are eligible to avail of this CU CPD scheme: Pathways graduates claiming the designation CU Ops. or CU Gov. who must partake of the scheme in order to maintain their designation. ACCUP graduates given the designation Recognised Credit Union Practitioner (RCUP) who must partake of the scheme in order to maintain their designation and/or accredited or fitness & probity status. Those currently grandfathered to provide insurance advice under the ROI Regulator s original 2006 MCR regime and therefore required to undertake CPD since that date to maintain their grandfathering status. Those likely to fall within a mandatory competency scheme in ROI in the future due to their providing advice to consumers on retail financial products, or arranging or offering to arrange retail financial products for consumers and to the exercise of specified functions; i.e. saving and loans. Board members, committee heads, managers, and senior staff who fall under the Central Bank s Fitness & Probity requirements as performing controlled functions and using CPD membership to help meet their fitness & probity standards. Credit union officers in Northern Ireland choosing to show CPD membership to go toward meeting their training & competence standards under the FCA / PRA. Credit union officers choosing to use CU CPD membership as a means to accessing free credit union specific e-learning programmes. 3 3 ILCU provides a suite of e-learning courses which cost 30 per course or are free to CU CPD members. Completion of six of these free courses in addition to CU Focus completes a full years CPD requirement. 7

8 The CU CPD regime operates on the basis of an individual being awarded CPD hours whenever they complete a formal training activity where this training is approved for CPD purposes. These awarded CPD hours will then be tracked and offset against a person s required CPD hours for the year. CPD hours can be gained by participating in paid and unpaid events run by the ILCU and external bodies and through appropriate internal training organised by the credit union. This can include: Current ILCU open-schedule and in-house training courses indicated as offering CPD credits. Relevant CPD seminars/road shows run countrywide by the ILCU (which will be advertised via circulation throughout the year). Web-based relevant e-learning courses such as those run via Relevant CPD activities or events by other providers and recognised for CPD purposes. Relevant and recognised CPD activities run by the credit union itself, subject to relevancy requirements as outlined in this document and recognition by the CU CPD panel. CU Focus CU CPD Requirements The CU CPD scheme requires 15 hours formal CPD to be completed annually. All CPD activity must be completed in the calendar year, i.e., 1 January 31 December. Surplus hours above 15 cannot be brought over to a subsequent year. CPD requires active involvement in a relevant presentation, seminar, lecture, class-room event or certified completion of appropriate e-learning tutorials and is not awarded to normal work activities such as meetings or everyday presentations. The content of CPD must relate directly to the role of the individual so CPD needs to be spread across topics to ensure that knowledge relates to the role undertaken by the individual and the role for which they are accredited. So, those offering shares & loans and insurance in their credit union must ensure they take CPD in the areas of shares & 8

9 loans and insurance. The maximum number of hours that will be awarded for any single topic in a day is four hours. The minimum unit of CPD that will be recognised is half an hour. Under the Central Bank Minimum Competency Code, 2011 at least one hour of CPD related to the area of Ethics must also be completed each year. This applies to all CU CPD members. Pro Rata Adjustment of CPD Hours In certain circumstances, such as statutory leave (i.e. maternity, carers leave, adoption leave or block parental leave), or for certified long-term illness (a continuous period of two months or more); a reduction in CPD hours may be permitted for a given calendar year. Please note that a prorata adjustment may only be applied provided the person is not carrying out any of the relevant functions for which he or she is a grandfathered or a qualified person while availing of the statutory leave (includes statutory paid and unpaid leave only). There is no reduction for part-time working or voluntary status, or for uncertified periods of leave such as holidays or career breaks. Details are available from the CU CPD member s area on Those claiming pro rata reductions are required to maintain documentation, (i.e. credit union letters, sick certificates etc.) to substantiate any claim for reductions in required CPD hours, and this may be audited. Relevancy Requirements for CPD The relevancy requirements for CU CPD will differ depending on your role within the credit union, i.e. whether you work in operations and fall under the terms of the Central Bank s Minimum Competency Code or whether you are involved in the governance of the credit union and therefore likely to fall within the Fitness & Probity regime. CU CPD Streams The CU CPD scheme is now made up of two streams representing those (mostly staff) who fall under the CU CPD Operations stream and those 9

10 (mostly volunteers) who fall under the CU CPD Governance stream. The diagram below represents the two streams: CU CPD Ops. (Operations) CU CPD Gov. (Governance) Those currerntly under the CB's MCC, (i.e. selling insurance). Including staff ACCUP/Pathways graduates & those grandfathered under MCC. Those not coming under the MCC. Includes volunteer ACCUP/Pathways graduates. Those staff coming under F&P as CF's or PCF's. Those likely to come under MCC Code (in the future through the selling of core products). Those volunteers falling under the fitness & probity regime as CF's or PCF's. Usually Staff (May include volunteers operating in an operational capacity). Will be Volunteers. Figure 1 - CU CPD Two Streams CU CPD Ops Stream The CU CPD Ops. stream applies to those CU CPD members (mostly staff) who currently fall under the Central Bank MCC or are likely in the future to fall under such a requirement for the provision of core credit union services. The relevancy requirements for those falling under the MCC are clearly specified under the Code itself. This means that the content of the CPD hours must be directly relevant to providing advice to consumers on retail financial products, or arranging or offering to arrange retail financial products for consumers and to the exercise of specified functions covered by the Code. There are eight product categories which fall under this Code: 1. Life Assurance 2. Pensions 3. Savings & Investments 4. Personal General Insurance 5. Commercial General Insurance 10

11 6. Private Medical Insurance 7. Housing Loans 8. Consumer Credit Agreements As credit unions currently offer advice in only two of these categories, Personal Insurances and Consumer Credit Agreements, the CPD undertaken should be focused on these areas and should be spread across a number of topics. More general topics, such as Data Protection or Anti Money Laundering training, should only make up a portion of your annual CPD. This is limited to four hours for any such single topic in a CPD year. Directly relevant for CU CPD Ops. members is interpreted as meaning the specific technical knowledge needed to provide advice to consumers on credit union financial products, or arranging or offering to arrange retail financial products for consumers and to the exercise of specified functions to members on credit union financial products. This does not include topics on wider skills such as soft skills (e.g. time management and management training), sales or member service skills or general IT skills (e.g. MS Word, Internet skills). Sales presentations would also not fall under the definition of relevant. Essentially, CPD must be related to the knowledge requirements required to provide advice to members on credit union products and services. The CU CPD scheme will outline which events are regarded as relevant to those falling under the operations stream with the note CU CPD Ops next to the number of hours available. CU CPD Gov. CU CPD Gov. applies to those (largely volunteers) who do not now (or are not likely in the near future) to fall under the MCC but may still have a CPD requirement; either through having taken a qualification such as Pathways or ACCUP or those who may be using CU CPD membership to help show fitness & probity (or training & competence in NI) for their role. The definition of relevant training for those in the Governance stream is wider than for those falling under the CU CPD Ops. stream - to reflect the differing governance role. Therefore CU CPD Gov. members will be able to claim for example soft skills, financial skills and IT skills training as CPD where it is held to be relevant to their governance role. 11

12 All ILCU courses will clearly indicate which are awarded CU CPD Ops. hours and/or CU CPD Gov. hours and external providers will also be awarded CU CPD where relevant based on this distinction. Those on the CU CPD Gov. stream will in all other respects be expected to comply with the regulations of the scheme including the 15 hour annual CPD requirement. Where to Gain CPD Hours 1. Open and In-house ILCU Courses The following current ILCU training events provide over 50 CPD hours per annum for both CU CPD streams as follows: ILCU classroom or in-house programmes Course CU CPD Ops. Members CU CPD Gov. Members Board Responsibility & Governance in Credit Unions 0 4 Compliance for Credit Unions (ROI) 4 4 Risk Management for Credit Unions (ROI) 4 4 Role of the Board Oversight Committee 0 4 Implementing Fitness & Probity 4 4 Dealing with Personal Insolvency Legislation 2 2 Role of the Nominating Committee 0 4 Role of the Chair 0 4 Role of the Secretary 0 4 The Role of the MLRO & AML Risk Assessment 2 4 Loans Assessment 4 4 Advanced Credit Control 2 4 Member Service through Compliance (ROI) 4 4 CU Operations (NI) 4 4 PRA Prudential Reporting (NI) 2 2 HR Issues 0 2 Assisting Members in Debt (ROI) 0 4 LP/LS Insurance

13 In-house only courses Strategic Planning 0 4 New Role of the Board 0 3 Data Protection 4 4 Credit Union Operations 4 4 Essential Member Care 0 4 Anti-Money Laundering (AML) 2 2 e-learning courses AML 2 2 Data Protection 2 2 Complaints Handling 2 2 Introduction to Ethics 2 2 The Credit Union Acts 2 2 Legal and Regulatory Environment 2 2 FSCS Deposit takers, What you need to know? 1 1 The Consumer Protection Code 2 2 LP / LS Insurance ILCU Seminars/Road shows ILCU seminars and road shows that are deemed to be relevant for each CU CPD stream will also be allocated CPD hours. ILCU holds a number of these per annum usually gaining 1-2 hours CU CPD each. The number of CU CPD hours approved will be indicated for each road show. CU CPD members must ensure they sign-in to any road show they attend. 3. Online CPD Courses All the ILCU e-learning programmes are awarded two hours CPD for both CU CPD streams. Current Courses include: Anti-Money Laundering (ROI) Anti-Money Laundering (NI) Data Protection (ROI) Data Protection (NI) Complaints Handling and the Financial Services Ombudsman (ROI) Complaints Handling and the Financial Ombudsman Scheme (NI) 13

14 Introduction to Ethics (ROI & NI) The Credit Union Acts (ROI) The Legal and Regulatory Environment (ROI) FSCS Training (NI) Consumer Protection Code (ROI) LP / LS Insurance (ROI & NI) Further e-learning courses are being developed on an on-going basis and all e-learning CPD courses can be accessed via E- Learning CPD courses are free to access for all CU CPD members. 4. Accredited Qualifications Relevant qualifications are also awarded CU CPD hours, e.g. the Pathways Certificate is awarded 12 CU CPD hours and each successfully completed module of the Pathways Diploma will also receive 8 hours CPD per module. Other relevant qualifications and examinations can be awarded CPD hours once recognised and registered as qualifying. 5. CU Focus Members of the CU CPD scheme only are entitled to claim four hours CPD per annum for the reading and assimilation of CU Focus. (CU CPD members who claim CU Focus may not also claim hours for QFA Update in the same year.) Accreditation of CPD Events All CU CPD events must be accredited by the CU CPD accreditation panel. The panel is made up of an independent group representing various roles within credit unions including directors, supervisors and staff. All organisations, (including the ILCU, credit unions and external training providers), offering events that they feel may qualify for CPD allocation are required to apply for CU CPD approval via an Event CU CPD Allocation Form available on Applications will be presented to the CU CPD Accreditation Panel for review and, if successful, an accreditation number will be issued for that event. Events must not be advertised as containing CU CPD hours unless this accreditation number has been provided to the organisers. CU CPD requests should be made at least six weeks before the event commences to ensure CU CPD allocation before the event. There is no guarantee that 14

15 an event will be accredited with CU CPD hours until it has been formally recognised and received an accreditation number. The content of all CU CPD events must be relevant to the stream(s) being applied for and those presenting will be expected to have qualifications and experience appropriate to the subject being presented. The CU CPD Accreditation Panel accredits all relevant ILCU, credit union in-house and external events for CU CPD hours and its decision of CPD allocation is final. Record Keeping It is the responsibility of each CU CPD member to keep an individual record of all CPD undertaken. ILCU has introduced an online CPD tracker for credit union personnel on to help record and manage CPD hours throughout the year. CU Learn will automatically record events such as ILCU relevant open-schedule courses, ILCU CPD seminars/road shows (if the CU CPD member has clearly signed in for the event), ILCU online courses and Pathways Certificate and Diploma qualification modules. CU Learn will also let you enter CU CPD hours in your individual record for approved courses run by the credit union itself or with other external training bodies by quoting the events CU CPD accreditation number. It is the responsibility of the individual to keep thorough records (for a period of six years) of all CPD activity should they be subject to audit. CU Learn allows the printing of certificates of completion for all ILCU CPD events. For those who leave the credit union CU CPD may be maintained by contacting the ILCU and informing of your wish to maintain CU CPD as a private individual. Annual Audit A sample of CU CPD members will be audited on an annual basis. Failure to provide adequate proof of attendance at courses will result in removal of those courses claimed from the CU CPD record. Should an individual be the subject of a spot check from ILCU or the Central Bank/FCA, they may be required to present documentation in support of their personal training records (i.e. receipts, certificates of completion/attendance, etc.). ILCU maintain the right at all times to monitor compliance with the CU CPD scheme and will remove members from the scheme should they fail to comply with its requirements. 15

16 Annual Return of CU CPD Hours CU CPD activity is recorded on a calendar-year basis (i.e. 1 January 31 December). CU Learn will be used to record CPD training throughout the year. 4 All CU CPD members must ensure that their CU Learn training record is complete by the end of the year. ILCU will check all CU CPD member records by January 31 st each year. Members will receive notification by shortly after this date confirming their hours as correct or noting any issues or shortfalls. Items added to your record for the previous year after the 31 st January will not be counted. Shortfalls Failure to complete and record the required 15 hours CPD will result (on the first occasion only in any five year period) in a carry-over of short hours to the following year. The member will be notified of their shortfall and required to complete this as well as their annual requirement the subsequent year. A second shortfall or failure to meet the previous year s shortfall will result in removal from the scheme. Removal from the CU CPD scheme Continued failure to complete the required hours or to meet the other various requirements of the scheme as outlined in this document (such as not completing an ethics course or not completing a broad range of relevant topics) will result in removal from the scheme. For CU CPD members who fail to maintain the requirements of CU CPD Ops this may affect your accredited status under the MCC and therefore make you ineligible to provide advice to consumers on credit union member-pay insurance products, or arranging or offering to arrange credit union member-pay insurance products and to the exercise of associated specified functions within the credit union. It may also affect standards under Fitness & Probity, affecting the ability to undertake a CF or PCF role in the credit union. 4 CU Learn is the new training administration system from ILCU. Registration to CU Learn is automatic once you join the CU CPD scheme. Those who have already joined the scheme will have been set up on the system and ed a user name and password. 16

17 Those who were grandfathered under the terms of the Central Bank s original Minimum Competency Requirements in 2007 (which at present only affects those providing advice to consumers on credit union memberpay insurance products, or arranging or offering to arrange credit union member-pay insurance products and to the exercise of associated specified functions within the credit union) will lose their grandfathering status. For those under CU CPD Gov., removal from the scheme may affect their fitness & probity status which can be taken into account when assessing their suitability for a CF or PCF role within the credit union. In all cases the credit union will be informed of any removal of a CU CPD member from the CU CPD scheme. Both the MCC and Fitness & Probity regime are also subject to Central Bank sanctions and failure of a credit union or individual to meet either regime can result in severe fines or penalties. Appeal of Decision to Remove from Scheme Any breach of the conditions of CU CPD membership may result in the loss of that membership and/or designation awarded for completion of a relevant qualification. Appeals against removal of membership can be made to the CU CPD Accreditation Panel. The CU CPD Accreditation Panel s decision is then binding. Reinstatement of CU CPD Membership and/or designation A person who has had their CU CPD membership and/or designation removed due to failure to comply with the CU CPD regulations will only be considered for reinstatement on a case-by-case basis and will be subject to at a minimum the following: completion of any previous shortfall or other outstanding CPD requirement payment of any backdated CU CPD membership fees 2 hours penalty CPD to be applied in the year of reinstatement 17

18 Reinstatement will only be offered to any individual once within a five year period. Alternatively an individual may complete a recognised qualification and reapply for CU CPD membership. Fees for CU CPD membership An annual fee for membership of CU CPD is billed to the credit union each year. Details of the amount are indicated on the CU CPD Registration Form. This fee is used to administer the scheme, develop and host free e- learning CPD courses and provide access to the CU CPD member s areas which is hosted on the ILCU s general training administration system - CU Learn. Membership fees are invoiced to the credit union after the 31 st January each year for that year s membership. If you or your credit union do not inform us that you wish to be removed from the CU CPD scheme the ILCU will continue your CU CPD membership and invoice the credit union. If you wish to be removed from the CU CPD scheme you must inform the ILCU in writing ahead of year end i.e., by December 31st. Note: Those who inform the ILCU of their wish to leave the scheme after December 31 st, or who are subsequently removed from the scheme, will not be entitled to a refund for that CU CPD year. Communications Communication to CU CPD members will be primarily through CU Learn (the ILCU s free to use training administration system) and via or mobile. CU CPD members will be registered for CU Learn (if not already registered) and be given access to the CU CPD member s area in CU Learn where they can view their CU CPD record at any time, take elearning courses, apply for pro rata adjustments to their CPD or register externally taken CPD courses. Under the terms of the Central Bank MCC credit unions are required to monitor the progress of their CU CPD members at least once in the first nine months of each year and again within six weeks of the year end. To 18

19 help with this requirement, we remind credit unions to check their CU CPD members status on CU Learn by September each year and again within six weeks of year end. (These reports can be printed by the credit union and retained on file). In addition any removal of a CU CPD member from the CU CPD scheme will be communicated to the credit union as necessary for the credit union to keep and maintain its Register of Accredited Persons and/or fitness & probity documentation. Your information may also be disclosed to the Central Bank (or FCA / PRA in NI) as required as outlined on the data protection notice on your CU CPD application form. Your CU CPD record is available to you at all times on (under Training Courses/CU CPD Members). If you believe the information contained within your training record to be inaccurate, contact your CU Learn Coordinator or alternatively the ILCU at to have this corrected. 19

20 Ten Frequently Asked Questions 1. What is CPD? CPD stands for continuing professional development. It is often linked to a professional qualification which is maintained through the taking of CPD. A CPD regime operates on the basis of an individual being awarded CPD hours whenever they complete a formal training activity. These awarded hours will then be tracked and offset against a person s required CPD hours for the year. 2. Who must get a qualification and do CPD? At present (2013) essentially only those officers providing advice to consumers on credit union member-pay insurance products, or arranging or offering to arrange credit union member-pay insurance products for consumers and to the exercise of specified functions in ROI credit unions are required to hold a qualification and/or undertake CPD. However, the recent application of a Fitness & Probity regime to credit unions requires those officers designated as controlled functions to have and maintain standards of fitness & probity. This will include the board, key committees, manager and senior staff of all but the smaller credit unions. At present there is no specific qualification or CPD obligation on NI credit unions, however the FCA does require that regulated entities have and maintain the training and competencies needed to operate soundly, effectively and in the interests of their members. 3. What are the Qualification & CPD requirements? Professional qualifications will often have CPD requirements attached to them. For those who hold the main MCC qualifications, (QFA, CUA, ACCUP or Pathways Diploma) and for those who are grandfathered the CPD requirements are 15 hours formal training per annum. Those falling under the Minimum Competency Code (MCC): The MCC applies to those providing advice to consumers on retail financial products, or arranging or offering to arrange retail financial products for consumers and to the exercise of specified functions. For credit unions however due to an on-going exemption on its core products the MCC only currently applies to member-pay insurance products. Those falling under the MCC must have a qualification as prescribed by the Central Bank of Ireland (CBI) - or have been grandfathered in and must take and maintain CPD on an annual basis. 20

21 Those falling under the Fitness & Probity (F&P) standards: Unlike with the MCC a specific qualification is not prescribed under the Fitness & Probity regime. It is likely that the CBI would expect some form of relevant qualification or experience of those who hold controlled functions, and if that qualification requires CPD, that that CPD must also be maintained. The Central Bank has stated in its Minimum Competency Code of 2011, (page 2), that minimum competency is one of the key concepts is assessing whether a person is fit to exercise a controlled function. 4. How do I go about meeting these new requirements? Those within credit unions who provide advice to consumers on credit union member-pay insurance products, or arranging or offering to arrange credit union member-pay insurance products for consumers and to the exercise of specified functions in ROI credit unions are required to hold a qualification and/or undertake CPD. Those exerting significant influence in larger credit unions through their role as a board or committee member will fall under fitness & probity and should also ensure that they are either adequately qualified or have relevant experience for their role. ILCU has developed the credit union Pathways qualifications as the minimum standard for those either falling under the MCC or Fitness & Probity standards. Gaining and maintaining a Pathways qualification through membership of the CU CPD scheme will therefore help in meeting your obligations. 5. What are the requirements of someone new to the credit union? For those new entrants who fall under the scope of the MCC they must have first undergone an induction training programme, and then be working under the direct supervision of a qualified person and be signed up to a relevant qualification. Details of new entrant requirements are listed in the Central Bank MCC Where can I get CPD hours? CPD hours can be gained by participating in paid and unpaid formal relevant training events which can be run by ILCU, external bodies or through relevant internal training organised by the credit union. For those falling under the MCC relevant has been defined as directly relevant to the provision of the eight retail financial products covered under the Code and in the general regulatory and compliance requirements around the provision of those products. CPD training can include: Current ILCU open-schedule and in-house training courses indicated as offering CPD hours. 21

22 Relevant CPD seminars/road shows run countrywide by the ILCU Web-based relevant e-learning courses such as those available on Recognised relevant CPD activities or events by other providers The easiest way to maintain CPD is to join a CPD scheme where the scheme will require you to take and return the required CPD on a regular basis. 7. How are CPD hours monitored? It is the individual s responsibility to keep a record of all CPD undertaken. Signing up to a CPD scheme such as CU CPD will greatly assist in maintaining CPD and meeting regulatory requirements as CU CPD will automatically track and monitor CPD requirements as well as providing access to CPD events. 8. What happens if I do not meet my annual CPD requirements? Any individual who fails to complete the required CPD hours in a given year has a chance to make up the shortfall by the end of the following year. This grace period will only be given once in any five year period. Failure to comply with any of the CPD requirements may ultimately result in the removal of a CPD designation or grandfathering status. Should an individual lose their CPD designation, they will need to be removed from the credit unions register and may not, therefore, be in a position to continue that role within the credit union. 9. What happens if I lose my CPD or grandfathering status? Cases will be dealt with on a case by case basis but usually to be reinstated any individual who has lost their CPD status will be asked to make up the shortfall for the previous year and in addition may be asked to complete penalty CPD to become reinstated. Where an individual is not meeting their MCC or Fitness & Probity requirements they may need to be removed from the credit unions register of accredited persons. 10. How do I sign up for CU CPD? Members may register using the CU CPD Registration Form available from the ILCU on 22

23 More Information The following links provide more information on CPD requirements: ILCU Circulations i.e. MCC Code Implications for Credit Unions, 5 th September 2011 and the ILCU Fitness & Probity Web page both on Management of Training for credit unions on the home page of CU Learn, Central Bank The Minimum Competency Code, September Central Bank Fitness & Probity Standards for Credit Unions, /default.aspx FCA / PRA FCA and PRA Handbooks For more information relating to any of the issues dealt with please also contact CU Learning & Development at: cucpd@creditunion.ie Call: Web: 23

24 Some Terms Explained Accredited Person ACCUP Approved Person CPD Controlled Function (CF) CU Learn Fitness & Probity A person who satisfies the standards under the MCC, (either through relevant qualifications or grandfathering). The credit union must keep and maintain a Register of Accredited Persons. Advanced Certificate in Credit Union Practice. The original qualification developed by ILCU to meet the Central Bank MCC. The term used in NI for those individuals performing certain functions within the credit union, such as manager, MLRO or Chair. Currently the Approved Person regime is under review in the UK. Continuing Professional Development. On-going training used to keep up to date with latest developments. Required for certain qualifications or for those grandfathered under the terms of the Minimum Competency Requirements. Also recommended to help show fitness and probity. The term applied to the activity carried out by those within the credit union who exercise significant influence on the running of the credit union, or are involved in overseeing compliance, and therefore subject to the rules of the Central Bank s (ROI) Fitness & Probity Regime. Applies to new CF roles from August ILCU s training administration system where all ILCU training is now booked and managed. CU Learn also runs the CU CPD scheme, provides access to e-learning and allows credit unions to run training and other key reports. The regime requiring those who exert significant influence on the running of the credit union to meet fitness & probity standards. Essentially the Central Bank requires credit unions to apply certain standards on those who hold key positions. Although no specific qualifications are listed as meeting these standards, in the absence of other relevant qualifications, the CBI have indicated that the holding of a recognised qualification and CPD 24

25 membership will help meet its fitness criteria. Grandfathering The term initially given to those with four or more years experience (as of January 2007), which removed them from the requirement to complete a qualification under the Central Bank s MCC. MCC MCR Pathways Pre-Approved Controlled Function (PCF) Minimum Competency Code, 2011 issued by the Central Bank in outlining the responsibilities and obligations of those providing advice to consumers on retail financial products, arranging or offering to arrange retail financial products for consumers and the exercise of a specified function. Minimum Competency Requirements. The original requirements from the Central Bank (2007) updated by the MCC in The name given to the new accredited qualifications designed by the ILCU and UCC to meet the MCC and fitness & probity requirements of credit union personnel. The same standards will apply as Controlled Functions except these individuals (Chair and Manager) must also apply to the Central Bank before being authorised to take up their role. Applies to new roles from August