How to fill the gap

Julie Hepworth, group regulatory manager at Perspective Financial Group, offers tips on how to complete your ‘gap-fill’ obligations.

The notion of qualification and ‘gap filling' in particular has been a thorny and uncertain issue over the last six months. To say that the waters were muddy would be something of an understatement, and while there may still be concern at an individual adviser level, about what gaps exist and what they should be filled with, there is now a far greater degree of clarity from the regulator.

This does not mean everything is plain sailing by any means. Indeed, there are some moral issues which will not go away, for example, the harsh reality that holders of a Level-3 qualification could meet the RDR professionalism requirements sooner than someone who has already chosen to exceed the minimum standards by reaching Level 6.

This is bizarre to say the least, as indeed is the wider question of how ethical it is to ask advisers who already hold a Level-4 qualification to gap-fill? But we shall leave those debates to one side for a moment and focus on the common dilemma for most advisers: How do I know what gaps I have to fill and what should I be doing now?

If we start with the FSA's Policy Statement 11/1: ‘Delivering the RDR - professionalism', many will have breathed a sigh of relief when it was confirmed that those holding an appropriate existing qualification will not have to take further exams if they do not wish to, but instead will have to gap-fill. As stated above, the wait for total clarity is not yet over, and we will be well into quarter two of this year before we find out who the first raft of FSA-approved accredited bodies are. So, what should advisers be doing between now and then?

Well, for those advisers that are already members of a professional body, most will have had the benefit of logging onto a personalised gap-fill tool to determine which gaps they will need to fill before being able to apply for a Statement of Professional Standing (SPS). For those that are not members of a professional body, currently the only alternative is to determine their own gaps by using the FSA's template in Appendix 7G of the TC Handbook.

My guess is that not many busy advisers will have the spare time to manually map their existing qualifications against 37 pages of new qualification standards. With the time it would take to complete this exercise and the potential loss of earnings, the question of joining a professional body rather than using the FSA template becomes irrelevant, but instead becomes a question of ‘which professional body shall I join?'

The answer to the quandary of which professional body to join depends upon the degree of consistency that accredited bodies employ. In theory, advisers should really join the body with which they hold the most relevant exams, but if standards for verifying gap-fill activity vary, it will inevitably sway some people's decision. The overall point however should be that the sooner that decision is made, the sooner the adviser will be able to map their gaps.

In light of this, my tips for what you should do now are:

• Don't delay. The important point at this stage is to determine what gaps you have and how many of those gaps you plan to address each month. Break it down into manageable chunks and be honest with what you feel you can achieve.
• Remember that gap filling cannot be left until December 2012. Advisers will need to leave enough time after filling all gaps to apply for their SPS in readiness for 1 January 2013.
• Remember it is acceptable to use any relevant retrospective CPD to fill gaps, providing you have adequate evidence.
• Most advisers (unless they hold a recent Level-4 qualification) will have a large number of gaps to fill for regulation and ethics, so this is a good starting point. Watch out for the free gap-filling courses that are being offered in this area.

The key point to remember is that evidence is vital - the regulator is not going to accept that a gap has been filled just on your say-so. Therefore, advisers should make it a rule to ensure they evidence all the CPD they complete from today. By doing this, you will be building up the necessary evidence to take you to the place you need to be and it will give you an easy way of determining whether you are moving forward at the right pace to ensure you make your destination.