CPD REQUIREMENTS QUESTIONS & ANSWERS Document 209002 The purpose of this Question and Answer (Q&A) document is to address questions posed by members as a result of the changes proposed to the CPD Qualification Standard (QS). The questions are separated according to the sections of the CPD QS as well as the new CIA CPD Monitoring Policy. CPD QUALIFICATION STANDARD SECTION 1: INTRODUCTION AND APPLICATION (INCLUDING DEFINITIONS) Section 1 indicates that the CPD QS is a minimum requirement for members in order to perform professional services pursuant to Rule 2 of the Rules of Professional Conduct. 1. What is the definition of professional services of an actuarial nature? The CIA Rules of Professional Conduct specifically define the term professional services as follows: Professional Services The rendering of advice, recommendations or opinions based on actuarial considerations including other services provided from time to time by a member to a client or an employer. The term of an actuarial nature is added for the purpose of the QS in order to limit the interpretation of other services in the definition. The qualifier of an actuarial nature was added to limit how broadly professional services could be interpreted. 2. I m the CEO of an insurance company and don t do any actuarial work. The closest I get is reviewing actuarial reports as do other board members, who are not actuaries. Would I need to comply with the CPD requirements under the new recommendations? If you are not providing services of an actuarial nature, then the CPD requirements do not apply to you and you can request an exemption under Section 3.1 of the QS. An exemption must be applied for annually. However, if you are doing work that is of an actuarial nature, then you must comply with the CPD requirements.
SECTION 2: REQUIREMENTS Section 2.2 explains that acceptable CPD activities must be relevant at the time they are completed and appropriate to support the member in maintaining his or her level of skill and knowledge as the actuarial profession evolves. 1. How do I know if an activity is relevant to me? In deciding whether to count an activity for CPD, you should ask yourself whether you learned something new or whether it caused you to think about something in a different way. It may also be an activity that will provide more in-depth knowledge of a topic of which you already have some knowledge (i.e., a refresher). An activity that is relevant for one member may not be relevant for another. For example, a new pension actuary may find a seminar that compares different pension accounting standards very relevant for his or her CPD purposes, while someone who has been doing work with the various Standards for several years may not. The new actuary might count this as CPD activity while the more experienced actuary may decide to not count it. Section 2.3 requires members to complete 100 hours of combined structured and unstructured relevant activities. 2. The definition of structured (as found in Section 2.1) is not sufficiently clear. Structured events must either be planned in advance or include multiple and varying points of view. Such activities are generally understood to provide a higher quality of training/development to the member when compared to self-taught activities. Examples of structured activities include: Sessions at a meeting of the Canadian Institute of Actuaries, or other recognized actuarial bodies, including luncheon speeches or keynote addresses by world-class experts; Seminars, courses, special meetings, webcasts and similar events held by insurance associations, actuarial/accounting /tax consulting firms, etc.; Actuarial club meetings; Employer-sponsored, in-house training programs and seminars; Participation on actuarial practice and industry committees; and Meetings with colleagues (planned or unplanned) that expand actuarial skill and knowledge. 3. A structured activity must be planned in advance. There are often very rich exchanges of viewpoints that may be triggered by an e-mail, comment, etc. As these are not planned in advance, it appears they would not be considered as structured. The committee agrees that such activity would be deemed structured and as such, the definition of structured has been modified such that a structured activity is one that is planned in advance or where more than one point of view is provided.
Sections 2.3.1 and 2.3.2 require that members do at least 12 hours of structured activities related to the member s technical skills, and a combination of four structured or unstructured hours related to professionalism. 4. What is an example of a technical activity? For a valuation actuary in an insurance company, a technical activity would include an internal department meeting or discussing new mortality MCCSR requirements. For a pension actuary, this would include attending a seminar on changes being proposed to the Pension Benefits Act. In both cases, it is understood that attendance/participation in these events contributed to the member s professional development (i.e., there was knowledge gained through the activity). 5. What is an example of an activity to satisfy the professionalism requirement? Examples of professionalism activities include reading CIA Rules of Professional Conduct, engaging in a conversation about changes to the CIA Bylaws, and attending a seminar on ethics. Other examples include: Company sponsored training on conflict of interest guidelines, code of conduct, privacy policy; Seminars on anti-money laundering; Discussions concerning corporate governance issues; and Professional conduct of another country/organization relevant to your practice. 6. What happened to the business and management requirements? The previous requirement to complete four hours of business and management activities was somewhat controversial many members really liked this requirement, while others did not. As a result, the requirement for specific business and management activities has been removed from the CPD requirements. However, while there is no longer a minimum number of hours a member must spend on business and management activities, he or she is still encouraged to utilize part of his or her CPD hours to develop business and management skills, and he or she can still count these hours towards his or her CPD requirements. 7. Even though it may not be a requirement, can you provide some examples of what qualifies as business and management activities? Examples of business and management activities include: Harvard ManageMentor elearning courses (offered through the CIA); CIA sponsored Communication and Business Skills workshops; Seminars on developing negotiation, presentation, or business writing skills; and Company sponsored management training including HR.
8. How do I record time spent on CPD activities that aren t really technical, professionalism or business and management-related? Some members may spend time on activities that are not obviously technical, professionalism or business and management-related. An Other category of activities has been added to the online Tracking Tool to allow for such activities. Members should remember to make sure such activities are relevant and appropriate to maintaining their level of skill and knowledge as the actuarial profession evolves. 9. If a member practices in more than one area, do they need 12 structured technical hours for each practice area? The current CPD requirement of 100 hours is a member-based minimum not a practice-based minimum and as such applies regardless of the specific situation of the member. At this point, members are only required to demonstrate that they meet the minimum of 100 hours, but members are encouraged to spend more than the minimum on continuing education. Members are also already required to be up-todate in their area of practice under the Rule of Professional Conduct No. 2 A member shall perform professional services only when the member is qualified to do so and this may require a member to do more than the minimum. Section 2.4 requires that members retain personal records of their CPD activities for a period of five years. 10. Why are members now being required to maintain records of CPD? This requirement is not new as the responsibility of members to record their CPD activities was set out in the original CPD requirement (November 1994), which became effective on January 1, 1997. Since then, members have been required to keep records of CPD for at least five full calendar years, and the CIA has had the right to ask any member to produce these records during this time. The most recent recommended changes do not alter the requirement to keep records. 11. Requiring retention of records for a period of five years seems excessive. The retention is not excessive when compared to other randomly audited activities such as Revenue Canada tax filings. The five-year period is also consistent with other actuarial bodies (the AAA and CAS require members to retain their records for six years; the Institute of Actuaries of Australia requires members to retain their records for five years.) 12. Are there any guidelines as to what records specifically must be retained for five years? The online reporting tool will give a member an idea of what information they should keep track of and for that reason, we encourage all members to use the online reporting tool on the CIA website to record their CPD activities. 13. What is meant by personal records? Can my employer maintain my records? An employer may retain the records of a member s CPD requirements. However, each member is ultimately responsible for the retention of the documents. If a member changes jobs, he or she is responsible for obtaining the records of CPD activities for the last five years from his or her employer. Each member is responsible
for the accuracy of his or her CPD records, regardless of who is maintaining the records. 14. Does all the supporting documentation need to be retained (e.g., articles, materials, documents)? No, these documents do not need to be retained. The member is required to keep accurate records as to what resource material was used. 15. What if I use the CIA s tracking tool to record my CPD, will the CIA retain my files for the period of five years? Yes. The CIA s online webtool is a secure database where all your records will be stored for the minimum of five years, even for those not required to file details. Alternatively, the tracking tool also includes a download feature that allows members to export all their records into a spreadsheet, which can then be saved to a personal computer for future reference. SECTION 3: EXEMPTIONS Section 3.1.1 provides an exemption to members who are not performing professional services of an actuarial nature including retired members. 1. According to my employment contract, I can take a two-year maternity leave. If during my maternity leave I do not do any actuarial work, am I eligible for an exemption? If the member is not providing professional services of an actuarial nature then he or she is exempt from completing CPD. In this case, the member would not have to complete CPD during her maternity leave but would need to meet the CPD requirement at the end of the calendar year following her return to actuarial work. Members, who have claimed exemptions with plans to become non-exempt in the future, are encouraged to continue and maintain CPD to the extent possible. 2. I have recently returned from maternity leave, what are the filing requirements under this circumstance? Are the CPD requirements pro-rated according to the length of my absence? Members returning from a leave of absence must meet the CPD requirements for the filing period immediately following his or her return to actuarial work. There is no pro-rating of CPD hours. 3. If a member who is currently exempt were to start practising as an actuary again, would he or she then be exempt for the first two years to allow him or her to build up the requisite hours? When a member resumes practising as an actuary, he or she is required to meet the full CPD requirements; there are no pro rata requirements. A member, who is exempt from CPD yet intends to return to being a practising actuary at some later date, is encouraged to maintain his or her current CPD. Members are further reminded that under Rule 2 a member shall perform professional services only when the member is qualified to do so.
Section 3.1.2 provides an exemption to members who are pursuing Fellowship and has written an actuarial exam/module sponsored by the CIA, SOA or CAS and who has not yet obtained his or her FCIA designation. 4. In October 2007, I obtained 25 Professional Development credits under the old system; would I still qualify for an exemption? Having completed SOA PD credits under the old system would qualify as having completed a SOA sponsored exam/module. 5. If I am still writing my exams, when must I complete CPD and file my first annual statement with the Institute? If you have not yet obtained your FCIA designation and in the last two complete calendar years you have written an actuarial exam/module sponsored by the CIA, the SOA or the CAS, you are eligible to claim an exemption from compliance with the CPD Qualification Standard. If you wish to be exempt, you must submit a statement to that effect. The CIA Secretariat will develop the necessary forms required to elect such an exemption. 6. If I am a recent Fellow, when must I complete CPD and file my first annual statement with the Institute? You are required to comply with the CPD Qualification Standard from the time you achieve your FCIA designation. However, for the first two complete calendar years following your FCIA, you are only required to file a statement to the effect that you are a new FCIA. After two years, you will have to confirm you have met the CPD Qualification Standard. For example, if at the time of filing (in early 2009) you are a recent FCIA (FCIA designation in 2008), you are only required to file an annual statement to that effect pursuant to section B(iv) of the CIA CPD Monitoring Policy. Section 3.3 provides an exemption to members who do not reside in Canada and who do no work in Canada. 7. Can you explain the exemption for Non-Residents? As described in Section 3.3, a member who does not live in Canada AND does no Canadian work AND is a member of another International Actuarial Association Full Member association may choose to comply with that other association s CPD requirements. The QS does not define residency but it is generally understood that the member s primary residence is located outside Canada, such a determination being made prospectively at the time of the exemption would apply (i.e., December 31 st ). Any ambiguity should be referred to the Committee on Continuing Education (CE) on a case-by-case basis for clarification.
POLICY ON MONITORING COMPLIANCE WITH THE SECTION B: REPORTING REQUIREMENTS CPD QUALIFICATION STANDARD Section B(i) requires a member who acted in a reserved role during the previous calendar year (and who is not otherwise exempt under Section 3 under the CPD Qualification Standard) to submit a statement to the effect that they are in a reserved role and to file a record of his or her CPD activities. 1. What is a reserved role? A reserved role is a role that legally requires an FCIA, usually pursuant to provincial or federal legislation or regulation. This would include appointed actuaries for insurance companies, actuaries who prepare funding valuations for registered pension plans and actuaries who certify the calculation of a criminal rate of interest. There are other situations where holding an FCIA may be a prerequisite. For example, auditors may require a group and health care actuary to sign an accounting valuation in respect of post-employment benefits. Because the involvement of an FCIA is not a legal requirement, this role is not considered to be a reserved role. Nevertheless, we encourage actuaries acting in a non-reserved role to consider using the online Tracking Tool to record their CPD activities. 2. Could you provide some examples or a list of what are these reserved roles? The following is not meant to be an exhaustive list, but a sampling of the work performed by actuaries that constitutes a reserved role. It remains the responsibility of the member to be aware of the work he or she is performing and for what purpose his or her work is being used. a. Appointed Actuary for an insurance company. b. An actuary who signs a statutory pension plan valuation report for funding purposes or a cost certificate as required under provincial or federal pension legislation or the Income Tax Act. c. An actuary who signs a Pension Benefit Guarantee Fund Assessment Certificate as required under the Ontario Pension Benefits Act. d. An actuary who signs a report on termination of a pension plan pursuant to provincial or federal pension legislation or the Income Tax Act. e. Members who do calculations on criminal rate of interest. f. An actuary who signs a Certificate of Insurance for a provincial automobile rate filing. 3. I m a pension actuary but only sign one or two funding reports a year. Am I considered to be acting in a reserved role? If you are acting in a reserved role even if only for a single assignment you are considered to be acting in a reserved role for CPD purposes. This means that you
must file a record of your CPD activities completed during the last two calendar years with the CIA. The easiest way of doing this is to use the online Tracking Tool. 4. What is the difference in the requirements for a member who is acting in a reserved role compared to a member who is not in a reserved role? The only difference is that a member acting in a reserved role must file a record of his or her CPD activities with the CIA. This is most easily done by using the online Tracking Tool. A member who is not acting in a reserved role is still required to maintain records of his or her CPD activities. The online Tracking Tool is a convenient means of doing this and we encourage all members to consider using the Tracking Tool for this purpose. Section B(iv) states that a member who obtained his or her CIA Fellowship designation during the last two complete calendar years must file a statement to that effect. 5. What must I file if I am a new Fellow? As a new fellow, you will be required to file a statement attesting to the fact that you attained Fellowship in the past two calendar years. 6. If I am a new Fellow acting in a reserved role must I file details of my CPD activities? No, as a new Fellow you are not required to file details of your CPD activities in the first two complete calendar years after you obtained your FCIA designation. 7. I obtained my FCIA designation in 2008, when is the first time that I must file details of my CPD activities. The first time you will be required to file and attest to having met all the CPD requirements is in early 2011, when you will be asked to submit your annual statement for the CPD accumulated for 2009 and 2010. SECTION C: MONITORING AND VERIFICATION Sections C(iii) and C(iv) allow for the EEC or its designated group to audit the personal records of members kept pursuant to Section 2.4 of the CPD QS to confirm the member has recorded the appropriate number of hours and that the CPD activities are relevant and appropriate to the member. 1. What will be audited? Any audit would initially focus on information contained on the Tracking Tool or other records kept by the member. First, the recorded hours would be compared to the minimum requirements in total and for each category (i.e., structured, technical, and professional). Second, the individual activity record details would be reviewed for questionable entries (i.e., one member has entered minutes instead of hours in the online Tracking Tool). Third, as CPD activities must be relevant and appropriate to the member, the member should be able to defend the activities if challenged.
2. What about the privacy of my records submitted to the CIA, including the CIA s online webtool? Like all information retained by the Secretariat, your CPD files are treated according to the CIA s privacy policy. Members of the Committee on Continuing Education and staff of the Secretariat who are responsible for running this program will have access to the files, for the purpose of monitoring and verifying members CPD pursuant to the standard and policy.