An update on CPD requirements

As most will know the basic annual CPD requirement is 35 hours of which 21 must be structured. Currently the FCA’s rules say that this is the minimum CPD for retail investment advisers, and if you’re doing other activities such as mortgages, you need to do additional CPD over and above this number.

Now, separately from the above and following the recent EU Insurance Distribution Directive which requires advisers carry out a minimum of 15 hours CPD annually if you sell protection products, the FCA have indicated they are taking what seems a remarkably pragmatic approach to this issue. They say they do not see the need to go beyond the minimum requirements of the directive, so rather than require that these 15 hours must be in addition to the current 35 hours, the 15 hours can be included as part of the total 35 hour total. What you will need to do however is to be able to show that you have done 15 hours on protection – so keeping your records clearly delineating this aspect becomes of importance.

FCA are not going to specify any split of the 15 hours between structured and unstructured – firms have discretion on that (although do bear in mind that within your overall 35 hours, the 21 hours structured requirement remains). For example, doing 20 hours structured CPD on investments, and 15 hours unstructured on protection, whilst meeting the overall 35 hour target, still leaves you one hour structured short. This would not be the case if one of the 15 hours on protection had been structured.