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«Compliance A Guide for Grandfathered Persons Am I compliant? The Central Bank of Ireland’s Minimum Competency Code (MCC, 2011) enhances ...»


A Guide for Grandfathered Persons


Am I compliant?

The Central Bank of Ireland’s Minimum Competency Code (MCC,

2011) enhances the minimum professional standards for all persons

who provide consumers with financial advice on products or undertake

certain specified functions.

These standards are essential for the protection of consumers who

place their trust in those working in the industry.

Therefore, those who work in an accredited role or are engaged in a specified function must be compliant with the standards as set out in the MCC, 2011.

These include:

® holding recognised qualifications ® being grandfathered in respect of a specific function ® being trained or supervised by a qualified or grandfathered person ® being fit and proper ® undertaking relevant Continuing Professional Development (CPD) Am I in an Accredited role?

You work in an accredited role if you perform any of the following


® Give advice to consumers.

® Assist consumers in making claims under contracts of general insurance.

® Determine the outcome of consumer claims arising under contracts of general insurance.

® Adjudicate on any consumer complaints.

“ All consumers need to have confidence that they are receiving the best possible financial advice and services at all times.

” We are committed to strengthening consumer protection by requiring minimum professional competencies and standards ” of all persons providing consumer advice and services.

Bernard Sheridan, Director of Consumer Protection Am I a Grandfathered Person?

You must meet all of the following conditions in order to be approved as a grandfathered person under the MCC, 2011.

® On 1st January 2007, you were dealing with retail financial products or the specified function for which you are availing of grandfathering.

® Between 1st January 1999 and 1st January 2007, you amassed four years experience carrying out the specified function in question.

® You were assessed by a regulated firm for grandfathering purposes before the 1st January 2008 and the results documented OR a regulated firm will assess you no later than 31st December 2012 and will advise the Central Bank as to the reason for this delay.

® Your compliance with the experience requirement was certified by a regulated firm.

® You have complied and continue to comply with all relevant CPD requirements (60 hours from 1st Jan 2008 - 31st Dec 2010 and 15 formal hours annually thereafter).

What CPD requirements must a Grandfathered person fulfil?

In the interests of consumer protection it is vital that you maintain the currency of your expertise and stay abreast of developments in the insurance industry.

Grandfathered persons must complete 15 formal hours of CPD each calendar year including 1 hour of ethics and 1 hour for each function you are accredited for.

Grandfathered CPD requirements in more detail:

® You must complete at least 1 hour of CPD each calendar year for each function you are accredited for.

® You must complete at least 1 hour of CPD each calendar year which relates to ethics.

® You must ensure the content of the CPD hours undertaken is directly relevant to the functions you are accredited for.

® You must participate in a CPD scheme operated by a relevant professional body.

® You must retain a written log where you have arranged your own CPD to show that you have satisfied the Central Bank of Ireland’s requirements.

® You must ensure that where you are grandfathered in respect of specific functions and hold a recognised qualification in respect of other functions, the content of your CPD must be relevant to both sets of functions.

® You may apply for a pro-rata adjustment of CPD for statutory leave or long-term illness leave (two months or more if properly certified).

Grandfathered persons may not:

® Carry over surplus CPD hours to the following year.

® Apply for a pro-rata adjustment of CPD for a career break, unemployment, part-time work, retirement or holidays.

“ ” This enhanced code now places an onus on both the firms and persons to comply fully with their supervision and professional development requirements.

Bernard Sheridan, Director of Consumer Protection Where can I do my CPD?

The Insurance Institute of Ireland offers to its members a range of CPD both Online and Face to Face. Irrespective of the medium you can be

guaranteed content that is:

® developed by industry experts ® up to speed on industry trends ® cognisant of legislative developments and their impact ® technically relevant

Online CPD with iiiConnect offers:

® comprehensive CPD accredited e-learning ® automated compliance integration with Professional Standards Advisory Board - General Insurance (PSAB-GI) ® flexible, anytime learning ® online booking tool for your CPD lectures

The CPD Face to Face Lecture Series offers:

® valuable insights from leading industry experts ® active engagement through panel discussions and Q&A ® professional networking and peer engagement ® iiiCard records your attendance and updates your PSAB-GI portfolio ® headline events on topical industry issues Who is keeping track of my CPD?

You should keep track of your CPD. Document a plan for the year and then monitor your progress against that plan.

You are obliged to monitor your CPD progress at least once within the first nine months and again before the last six weeks of the year.

Your line manager is responsible for regularly reviewing your CPD which may also be audited by the Central Bank of Ireland.

In all cases CPD is monitored for hours completed and relevance of content.

Can I get help managing my CPD?

The Professional Standards Advisory Board for General Insurance (PSAB-GI) supports and monitors the CPD of The Insurance Institute of Ireland graduates (CIP, C/Dip L.A., Dip PMI, APA) and Compliance Grandfathered members who are regulated under the Central Bank of Ireland’s Minimum Competency Code (MCC, 2011).

PSAB-GI provides a service that allows insurance professionals and companies to plan and monitor their Continuing Professional Development. However, you are ultimately responsible for managing your CPD and ensuring that you are a compliant professional.

Any CPD you complete with The Insurance Institute of Ireland, either Online or Face to Face, is reflected in your records on PSAB-GI.

However, should you complete additional accredited CPD you must manually add this to your PSAB-GI record.

–  –  –

If you fail to complete 15 formal hours in any calendar year you can make up the shortfall by the end of the following year. However, if you fail to complete 15 hours formal CPD more than once in any 5 year period you will be removed from your employer’s Register of Accredited Persons.

Any breach of CPD requirements must be held on the regulated firm’s records. Further breaches may result in the removal of your grandfathered status.

You can be restored to the Register of Accredited Persons once you have completed your CPD and complied with all other aspects of the MCC, 2011.

How can I future proof my career?

As a Grandfathered person working in the insurance industry, you have strong proven experience.

However, in today’s market experience alone is not enough.

Gaining professional qualifications:

® protects your position in a competitive market ® affords you opportunities for career progression ® entitles you to use industry recognised designations ® develops your competence and credibility with consumers and colleagues alike You can get started with the Accredited Product Adviser (APA) which is a good stepping stone to the CIP designation. Alternatively you can undertake the PDI qualification which will provide you with the CIP desigantion which is the industry benchmark.

On successful completion of relevant III exams you can add 8 hours CPD per module to your annual CPD returns.

How do I get started?

As a Grandfathered person you may complete a recognised qualification which is relevant to the advice you give. The Accredited Product Adviser (APA) is a new programme which has been recognised by the Central Bank of Ireland as meeting their revised Minimum Competency Code (MCC, 2011). The APA designation is awarded upon successful completion of the programme and is available in three separate product categories - personal general insurance, commercial general insurance and private medical insurance.

The APA programme for each of the product categories consists of two general modules, ‘The Nature of Insurance’ and ‘Compliance & Advice’ plus one additional module of your choice which relates to your area of work.

If, for example, you work in both personal lines and commercial lines insurance then you need to complete the core general insurance modules (PDI01 and PDI02) plus two additional insurance modules (PDI03 and PDI04). Once you have successfully completed these four modules, you will receive the APA designation in both the personal and commercial general insurance product categories.

Accredited Product Adviser (APA) Course Structure

–  –  –

Commercial General Private Medical Personal General Insurance (PDI04) Insurance (PDI05) Insurance (PDI03) Each module of the APA programme also builds towards the Professional Diploma in Insurance (PDI) which is a level 7 Diploma on the National Framework of Qualifications. Therefore by successfully completing your APA you will already be some of the way towards completing the PDI (designation CIP).

The Professional Diploma in Insurance (PDI) is the benchmark qualification for the general insurance industry. The PDI is an academic qualification within the School of Professional Finance and is awarded by University College Dublin. The III additionally awards the professional designation of CIP to successful graduates.

If you are unsure about the right qualification route for you, please contact your HR or Training Manager to discuss which is more applicable.

To learn more about the PDI and other qualifications check out the current Prospectus at www.iii.ie/coursesandqualifications.

Where do I go for help?

The prospect of studying for exams may seem daunting for some people but The Insurance Institute of Ireland has developed a series of study tools to help and support you along your exam journey.

iiiPlus includes:

® online membership application ® online application for examinations ® exam permits, result letters and examiner feedback downloads ® your full academic record

iiiConnect includes:

® automated study planner ® study guides ® key points per chapter ® webinars ® online mock exams ® member, student and lecturer blogs Face to Face Tuition To complement and enhance your Online learning, we provide Face to Face tuition sessions in advance of each exam sitting. These sessions


® study skills ® exam preparation ® feedback on previous exam sessions ® case studies The main mistake that students make is not taking sufficient time to study the course. Insurance exams are relatively straightforward and if you give yourself enough time to study, you should pass them.

–  –  –

Disclaimer: This publication has been prepared by The Insurance Institute of Ireland for the purpose of informing personnel working in the insurance sector and other interested parties. It should not be relied upon as providing legal, financial or other professional advice. While every effort is made by The Insurance Institute of Ireland to ensure the accuracy of the information provided, no guarantee or warranty as to accuracy is given, nor may be implied. The Insurance Institute of Ireland accepts no liability for any damage or loss of any kind arising in consequence of the use of information contained herein. Advice should always be sought on particular issues from suitably qualified professionals.

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