FAIS FIT

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FAIS FIT PROPERBEYOND 2009

• JANE APPASAMY

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Road Map

• Background and Context
• Why it all began
• Where it all began
• How F P has evolved
• Going forward into 2010
• The old the new 2004 vs 2008
• Importance of DOFA
• Transitional generation versus
  non-transitional
• Competence focus

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Why it all began?

• Image of industry tainted by unscrupulous/dishon
  est behaviour
• Professionalizing industry meant qualifications,
  experience and accountability for staying current
  (like most other professions)
• In order for Financial Planning seen as a serious
  career choice, had to have serious criteria

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Where it all began

• FAIS introduced into the financial services
  world2004
• Determination of Fit Proper 2004
• All the fuss was about Columns 1,2,3 and 4!!!
• Concern at the time meeting column 4
  requirements
• No CPD
• No Regulatory Exams
• No transitional arrangements
• Just Financial soundness Honesty Integrity,
  Operational Ability, Competency (S.H.O.C.)

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2008 Fit Proper requirements
NEW
NEW
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How Fit Proper has evolved
BOARD NOTICES 103,104,105,106, of 2008
DETERMINATION OF FIT PROPER 2004
Column 3 4 requirements Entry deadline
requirements.
Qualifying criteria Relates to knowledge
skill. List of Recognised Qualif Content must
satisfy the qualifying Criteria.
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Date of first appointment

• Critical to determine whether transitional or
  not
• Break in service take original date of
  appointment in industry

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The 04-09 transitional generation

• All representatives appointed between September
  2004 and 31
• December 2009 can be grouped into the following
  groupings

CHOICE credits/whole qual.
Group 1 Appointed between September 2004
31 December 2007
Group 2 Appointed between 1 January 2008
31 December 2009
CREDITS 31 DEC 09 DEADLINE
QUALIFICATION RE 2011 2013 DEADLINE
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TRANSITIONAL versus NON-TRANSITIONAL
T R A N S I T I O N A L
Appointed 2004-2007
Appointed 2008
Appointed 2009
BEYOND 2009..
Appointed 2010 onwards
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Competence in more detail

• Experience
• Qualifications (qualifying criteria)
• Regulatory Exams

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Qualifications unpacked

• 1. GENERIC G
• - Content generic
• - Also complete product specific Regulatory Exams

2. SPECIFIC S - 80 of contents specific - If
completed end 2009 exempted from product specific
RE - Falls away from Jan 2010
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Qualifications unpacked
3. SPECIFIC SP - Match qualifying criteria 100
in terms of contents - Exempted from product
specific RE - Applies only from 2010 onwards
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Beyond 2010 04-09 generation

• Did not meet deadline of Dec 2009
• No longer fit and proper
• Remove from Representative Register
• 31 December 09 debarment and must follow
  reinstatement process
• E.g. 20 Dec 09 - remove with 3A, not debarment,
  no reinstatement necessary (1A)
• FSP competitors non-advice positions
• Awaiting clarity from FSB re requirements.
• Reintegration to advice-giving position

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The 2010 onwards generation
Experience -Must be product specific -Can
be gained under supervision -Depends on product
subcategory

• Qualification
• -Completed qualification
• from list of recognised
• qualifications appropriate
• Can be obtained under
• supervision

Regulatory Exam -Level 1 must be completed 2
yrs from appt. -Level 2 within 6 yrs from date
of first appt. -May be completed whilst under
supervision
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Thank you