CPD Training requirements for AFSLs not providing personal advice

Sophie Gerber

Sophie Gerber

Sophie is the director of both Sophie Grace Legal Pty Ltd and Sophie Grace Pty Ltd. Sophie has worked with some of Australia’s largest financial services organisations in compliance, legal and operational roles. She has also worked with small businesses to provide tailored solutions with a strong understanding of business practicalities as well as obligations to regulators.


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For AFSLs whose training year is set to align with the financial year, it is time to ensure the annual continuing professional development (CPD) training requirements are put in place through a new training plan for relevant staff. Even if your CPD training aligns with the calendar year or some other timetable, it’s important to make sure you keep up training consistently throughout the year to avoid a last-minute rush.

How many CPD hours are required?

Although ASIC does not specify a minimum requirement of CPD hours for Responsible Managers and representatives under an AFSL which doesn’t provide personal advice, twenty (20) hours is generally accepted as the industry standard. Responsible Managers, directors, advisers and other employees should consult their training plans (or Compliance Officer) and also ensure they are recording details of all CPD hours completed including the following as a minimum:

  • training type (e.g. publication, conference, in-house training);
  • training area (e.g. general knowledge, ethics, compliance);
  • date and duration; and
  • name of the training provider.

What areas of training are required?

All Responsible Managers and representatives must participate in a professional development program in order to meet the competency requirements set out in RG 104.  Staff working AFSLs dealing with retail clients should also ensure they are complying with RG 146.

Training must be continuously conducted at an appropriately high level and cover:

  • all broad aspects of the AFSL obligations, such as general compliance, legislative knowledge, regulatory updates;
  • knowledge related to the authorised products and services under the AFSL; and
  • knowledge specific to individuals’ role within the organisation.

Each Responsible Manager and representative should have a new training plan prepared at least annually for the following twelve (12) month period.

Training plans should address how the Responsible Managers and representatives will:

  • maintain and develop knowledge and skills that are appropriate for their responsibilities;
  • update their knowledge and skills, especially in areas where there is continual change (e.g. legislation, regulatory policies and standards, economic and financial developments, new financial products or new market practices); and
  • set objectives to be met, such as the desired changes in knowledge, skills and/or performance at the end of the training year. 

Background

Completing the CPD requirement each year is a simple way for AFSL holders to ensure they are maintaining their organisational competence to provide financial services. Because of the number of hours required to meet the requirements, Responsible Managers and employees of AFSLs should ensure they are completing CPD hours throughout the year rather than having to put aside a large chunk of time right before their company deadline.

Senior Management should review the CPD training progress of all representatives as well as themselves to ensure they too are completing the required hours.

For more information on CPD training requirements and how we can assist you, please contact us.

Further Reading

Sophie Gerber

Sophie Gerber

Sophie is the director of both Sophie Grace Legal Pty Ltd and Sophie Grace Pty Ltd. Sophie has worked with some of Australia’s largest financial services organisations in compliance, legal and operational roles. She has also worked with small businesses to provide tailored solutions with a strong understanding of business practicalities as well as obligations to regulators.